'PE firms that place employees on the boards of public companies bear heightened risks that they will obtain nonpublic material information through their representative occupying dual roles,' warned an SEC official.
Managers and compliance professionals need to be identifying mission critical systems, constantly engaging with IT, implementing regular training and maintaining heightened levels of communication.
CCO and former SEC enforcement branch chief Scott Pomfret gives his advice on carrying out an annual review in this excerpt from The US Private Equity Fund Compliance Companion.