Historically, investments in private funds have been reserved for large institutions, defined benefit pension plans, sovereign wealth funds and very wealthy individuals. In recent years, though, the notable difference in returns between private investments and those available in the public markets has increased pressure to expand access to private-market investments for “Main Street” investors. Partially in response to this pressure, in recent months, both the Securities and Exchange Commission (“SEC”) and the Department of Labor (“DOL”) have undertaken initiatives to expand access to these funds. At the SEC, these initiatives include abandoning a longstanding informal position that had significantly limited registered funds’ ability to invest in private funds, while a recent executive ord

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