Who Pays for AI? Expense Allocation, Soft Dollars and Disclosure Risk
AI spend is showing up everywhere in the manager P&L — data subscriptions, model licenses, compute, vendor tools, and internal builds. What's less settled is who should bear those costs, and the answer carries real regulatory weight. Is an AI research tool a fund expense or manager overhead? Can it be paid through soft dollars or a research payment account when the same tool also benefits the management company? And do your current disclosures actually describe what you're doing today?
Join us on the afternoon of July 28th for a practical session with Barbara Niederkofler, Co-Chair of Investment Funds, Akin and Suzan Rose, Senior Advisor, AIMA. They will cover the classification of AI-related expenses, the mixed-use problem when a tool serves both the fund and the manager, the limits of the Section 28(e) safe harbor — including where AI spend risks falling outside it entirely — and what regulators and investors now expect to see in offering documents, Form ADV, and DDQs.
This is an area where practices are evolving faster than disclosures, and we expect a lively discussion.
Speakers:
- Barbara Niederkofler, Co-Chair of Investment Funds, Akin
- Suzan Rose, Senior Advisor, AIMA
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