Private Funds In Focus

NEW YEAR'S RESOLUTIONS – ANNUAL FILING OBLIGATIONS AND COMPLIANCE MATTERS FOR PRIVATE FUND MANAGERS

As the new year begins, private fund managers should take some time to consider various action items that are potentially applicable to private fund managers, some of which may be new for many managers in 2013. For a quick summary of many of these items, see the chart on pages 6-8.

Section 13

Under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (the Exchange Act), any person or "group" of persons that directly or indirectly acquires beneficial ownership of more than 5% of any class of equity voting securities that is traded on a U.S. exchange (including Nasdaq) may be required to file a Schedule 13D or Schedule 13G. If one or more of a manager's funds currently holds, or at any time in 2012 held, in the aggregate more than 5% of such publicly traded securities, the fund or funds may be required to file an initial or amended Schedule 13D or