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Forums > Marketing Guidance for Private Fund Managers > Hedge Fund Mention
 
 


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ACA Webcast Attendee
    07/27/10 at 03:43 PMReply with quote#1

It seems misleading to not mention having a hedge fund at all when listing what your firm does.  So what is okay to say on a web site?  What about in the ADV schedule F?

ACA
    07/29/10 at 03:09 PMReply with quote#2

Advisers should not mention their private funds on publicly available portions of their website.  Advisers may discuss their firm history, employee bios, investing philosophy, and strategies.   The SEC expects that advisers to private funds discuss arrangements related to such funds in Schedule F where required.  So, for example, performance/incentive fee arrangements should be disclosed along with related conflicts of interest.  The new Part 2 of Form ADV will require a discussion of any relationships or arrangements with an “investment company or other pooled investment vehicle”, including a “hedge fund”. The SEC Staff has noted that information in the Form ADV is not deemed to be a general solicitation if it provides required information.

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