Generated by All in One SEO Pro v5.0.1.1, this is an llms.txt file, used by LLMs to index the site. # alternative fund pllc legal & business matter law firm to private and public fund managers across venture capital, hedge funds and private equity firms ## Sitemaps - [XML Sitemap](https://afundpllc.com/sitemap.xml): Contains all public & indexable URLs for this website. ## Posts - [The SEC just raised the bar for "qualified client" status](https://afundpllc.com/the-sec-just-raised-the-bar-for-qualified-client-status/) - On April 28, 2026, the SEC issued a final order adjusting the dollar thresholds under Rule 205-3 of the Investment Advisers Act, effective June 29, 2026. The assets-under-management threshold rises from $1.1 million to $1.4 million, and the net worth threshold rises from $2.2 million to $2.7 million (excluding the value of a primary residence). - [Fund Managers with a Clearer Path to General Solicitation Under Rule 506(c)](https://afundpllc.com/sec-no-action-letter-gives-fund-managers-a-clearer-path-to-general-solicitation-under-rule-506c/) - On March 12, 2025, the SEC's Division of Corporation Finance responded to a March 6, 2025 request from Latham & Watkins LLP and agreed that an issuer can satisfy Rule 506(c)'s "reasonable steps" requirement to verify accredited investor status simply by requiring a high minimum investment — at least $200,000 for individuals or $1,000,000 for - [Gary W. Mair, Esq. (Managing Partner)](https://afundpllc.com/gary-w-mair-esq/) - Gary Mair works with pioneer private fund managers and leading private fund organizations across all legal and business matters of a private fund enterprise. - [SEC’s Fund Manager Priorities in 2025](https://afundpllc.com/secs-fund-manager-priorities-in-2025/) - For 2025, the Securities and Exchange Commission’s Division of Examinations announced its 2025 exam priorities for "registered" investment advisers. Next year’s examinations will prioritize areas such as fiduciary duties and standards of conduct for investment advisers, and cybersecurity, artificial intelligence (AI), and anti-money laundering (AML) for various market participants. In addition to conducting examinations in - [Reinstatement of New Business Ownership Disclosure Rule Launched](https://afundpllc.com/a-new-business-ownership-disclosure-rule-launched-but-many-dont-know-about-it/) - A new business ownership disclosure rule became effective in 2024 but many do not know about - [Florida registration of Investment Advisers and Private Funds - Significant Change](https://afundpllc.com/florida-registration-of-investment-advisers-and-private-funds-significant-change/) - Effective October 1, 2024, Florida allows for both increased opportunities for Florida-based businesses to raise capital within Florida and strengthened licensing and anti-fraud provisions substantially revising Florida Securities and Investor Protection Act for Florida exemption of investment advisers and its private funds as well as forms and types of private fund offerings for exempt investment - [Commodities Futures Trading Commission on September 12 issued final changes to Rule 4.7 “qualified eligible person” (QEP) applicable to private funds and managed accounts.](https://afundpllc.com/commodities-futures-trading-commission-on-september-12-issued-final-changes-to-rule-4-7-qualified-eligible-person-qep-applicable-to-private-funds-and-managed-accounts/) - Under the prior definition of a QEP, certain persons (including natural persons who are accredited investors, among others) must meet one of two compliance thresholds or a combination of the two in a private fund. The newly adopted Portfolio Requirement doubles the amounts of the two thresholds: The Securities Test will be set at $4 - [Crypto Assets - SEC Relief for Registered Investment Advisers](https://afundpllc.com/crypto-assets-sec-relief-for-registered-investment-advisers/) - The US Securities and Exchange Commission Division of Investment Management Staff recently issued a no-action letter permitting, among, other things, registered investment advisers to use state trust companies to custody crypto assets. This position is an indication of the increased acceptance of Crypto Assets as an asset class and the increased demand for Crypto Asset - [Family offices](https://afundpllc.com/family-offices/) - Family offices are a source of capital for smaller, emerging managers. Traditionally seeking to chase returns and investing in smaller and nimble managers offering an opportunity for start-ups to emerging managers seeking capital. Regulatory changes are also shaping the investment environment. The US Securities and Exchange Commission recently provided guidance in an effort to expand - [Crypto - SEC Seminal Interpretation - March 2026](https://afundpllc.com/crypto-sec-seminal-interpretation-march-2026/) - March 17, 2026 - U.S. SEC, “Application of the Federal Securities Laws to Certain Types of Crypto Assets and Certain Transactions Involving Crypto Assets”. The interpretation is an effort to establish a clear federal regulatory framework for crypto assets This seminal interpretation is the first step implementing the SEC’s rulemaking agenda related to crypto assets - [SEC Exam Priorities in 2026](https://afundpllc.com/sec-exam-priorities-in-2026/) - U.S. SEC Division of Examinations Announces 2026 Exam Priorities On November 17, 2025, the U.S. Securities and Exchange Commission (SEC or Commission) Division of Examinations (Division) published its annual examination priorities (Priorities) outlining areas of perceived risk and topics that the Division plans to focus on in the new fiscal year. Investment Advisers Adherence to - [How to Mitigate Offshore Start Up Fund Formation Costs](https://afundpllc.com/how-to-offset-offshore-fund-offering-cost/) - Relying on our years of pragmatic legal and business fund manager experience and know-how across the fund manager organization enterprise, we have executed a number of viable offshore start-up private fund vehicles for clients seeking to manage fund formation start-up costs and increase the likely-hood of the investment manager's short term fund formation and long-term - [onshore-offshore private firms](https://afundpllc.com/onshore-offshore-private-firms/) - law firm to private fund startups to establish private funds onshore or offshore fund formation - [SEC New Rule Impacting Investment Advisers](https://afundpllc.com/sec-new-rule-impacting-investment-advisers/) - SEC adopted changes to comply in 2024 aimed at non-registered and registered advisers (IAs) to private funds) - [CFTC - New Rule](https://afundpllc.com/cftc-new-rule/) - CFTC new rule impacting definition of "qualified eligible person" exemption to avoid regulatory review of documents - [hedge funds](https://afundpllc.com/awards-win/) - [private fund start ups to established](https://afundpllc.com/business-partners/) - start a private fund, fund formation hedge funds, private equity and private fund enterprise - legal and business expertise across the enterprise - [private equity funds](https://afundpllc.com/happy-clients/) - private equity starts-ups, formation and build-out - [Brian McNally, Esq.](https://afundpllc.com/brian-mcnally-esq/) - Brian F. McNally has almost 30 years of regulatory experience as investment management lawyer and compliance professional, including senior roles at the U.S. Securities & Exchange Commission, in private law practice at two national law firms, and in house as general counsel and chief compliance officer of a prominent investment adviser. Brian also served as - [Grace Brescia](https://afundpllc.com/grace-brescia/) - Grace’s professional career spans more than twenty-five years across fund managers and broker-dealers. Grace functioned as a manager, partner, member, and Chief Compliance Officer of both broker-dealers and investment advisors, and acquired extensive expertise in private fund management, trading floor operations, FINRA/SEC/NFA/CFTC reporting, underwriting and supervisory control procedures. Grace maintains particular familiarity with Dodd-Frank, FSA, ## Pages - [Home](https://afundpllc.com/) - Boutique NYC securities law firm for hedge fund, private equity, and venture fund managers. From start-up or launching a fund, formation, build-out, SEC/CFTC compliance, and outsourced GC/CCO support from former in-house counsel. Schedule a consultation. - [Key team members](https://afundpllc.com/private-fund-manager-focused-team-2/) - attorneys who have actually held executive titles inside funds, GC, CLO, CCO, and COO— in addition to an outside advisor at a law firm The Private Fund Attorney Team Built by Former Fund Executives - [Meet the Team](https://afundpllc.com/private-fund-manager-focused-team/) - Meet the partners of Alternative Fund PLLC — former General Counsel, CCO, and COO to firms including BNP Paribas, Nikko Asset Management, and Anchor Risk Advisors, a strategic partner with XL Re. - [About](https://afundpllc.com/about-us/) - We've helped managers start a fund, launch a fund, and grow past a billion in AUM — because our partners have sat in your seat as General Counsel, CCO, and COO, not just advised from outside. - [Let's Talk About Your Firm](https://afundpllc.com/contact/) - Schedule a free consultation with a private fund attorney. Call 917-558-7794, email office@afundpllc.com - [Private fund manager focused expertise](https://afundpllc.com/our-private-fund-manager-expertise/) - providing private fund managers a nimble and pragmatic alternative law firm with deep know-how -.private fund strategy, execution or support across enterprise - [Resources](https://afundpllc.com/private-fund-manager-resources/) - "select private fund articles and regulatory notices" - [Scope of what we do](https://afundpllc.com/scope-of-private-fund-know-how/) - [Disclaimer](https://afundpllc.com/disclaimer/) - The alternative fund pllc web site provides general information about the firm. Although this information may be considered advertising under the rules of some courts, our site is not intended to advertise our legal services, to solicit clients, or to provide legal advice. The purpose is to provide information, with the understanding that the information - [Blog](https://afundpllc.com/blog/) - [Sample Page](https://afundpllc.com/sample-page/) - This is an example page. It's different from a blog post because it will stay in one place and will show up in your site navigation (in most themes). Most people start with an About page that introduces them to potential site visitors. It might say something like this: Hi there! I'm a bike messenger ## Service - [Fund & Firm Formation for Emerging and Established Fund Managers](https://afundpllc.com/service/private-fund-formation/) - Fund formation counsel for emerging and established managers — onshore/offshore structures, offering documents, blue-sky filings, and investor-ready compliance frameworks. - [Partner Level Support](https://afundpllc.com/service/private-fund-firm-wide-know-how/) - Partner-level strategic guidance across fund formation, compliance, operations, and asset-raising — built for managers who need an edge with sophisticated investors. - [A Private Fund Attorney Team That Has Actually Worked From the Inside](https://afundpllc.com/service/private-fund-attorneys/) - Private fund attorneys with real GC, CCO and COO experience at major asset managers. Securities, corporate and regulatory counsel from start-up to institutional scale - [Our Edge](https://afundpllc.com/service/our-private-fund-manager-edge/) - Partner-level 20+ years of both law firm & in-house General Counsel, CCO, and COO experience at hedge funds- global asset managers — without big-law overhead. - [Separates Us From The Pack](https://afundpllc.com/service/separate-from-the-private-fund-pack/) - Alternative Fund PLLC helps fund managers close the gaps that make sophisticated investors walk away — to separate from the pack, not blend into it. - [Registered or Exempt Firm Wide Know How to Manage Funds](https://afundpllc.com/service/private-fund-firm-wide-execution/) - `Partner-level strategic guidance across fund formation, compliance, operations, and asset-raising — built for managers who need an edge with sophisticated investors.` - [Market Your Fund the Right Way — and Win the Allocation](https://afundpllc.com/service/private-fund-marketing/) - Legal and strategic guidance on fund marketing, pitch books, and investor solicitation rules — built to help hedge fund and PE managers win allocations. - [C-Suite Expertise, Without the C-Suite Overhead](https://afundpllc.com/service/private-fund-c-suite-expertise/) - Bespoke, co-sourced or fully outsourced GC, CCO, and COO support. Get GC, CCO, and COO-level expertise without a full-time hire. Fractional and co-sourced support for hedge fund, PE and VC managers from former fund executives. - [The Transactional Counsel Behind Your Fund's Everyday Business](https://afundpllc.com/service/private-fund-partner-transactional-corporate/) - Governance documents, partner agreements, side letters, and counterparty contracts for hedge fund, PE and VC managers — from attorneys who've run the business. - [Get Investor-and SEC-Ready Before You Need To Be](https://afundpllc.com/service/private-fund-risk-management/) - Get investor- and SEC-ready before you need to be. Gap analysis, AIMA-standard DDQ prep, and risk-management frameworks for hedge fund and PE managers. - [Investor Solicitation Support](https://afundpllc.com/service/private-fund-investor-due-diligence/) - marketing a private fund under private placement rules - [Compliance and Operations Built to Survive an SEC Exam](https://afundpllc.com/service/private-fund-compliance-operations/) - Build an investor-ready compliance and operations framework with a private fund attorney team that has served as CCO and COO. Manuals, controls, gap analysis. - [Alternative options to launch a more viable fund](https://afundpllc.com/service/private-fund-firm-wide-know-how-2/) - "We have executed a number of onshore and offshore private fund vehicles for clients which seek to manage start-up costs and increase long-term firm viability. The decision where to form a private fund, form of structure and how to execute can offset material costs such as filing fees, legal fees and ongoing jurisdictional requirements. For example, fun f formation and start up expertise and growth throughout life cycle ## Testimonial - [RMCEF LTD](https://afundpllc.com/testimonial/risk-managed-closed-end-funds-ltd/) - Launched an offshore start-up master-feeder structure into existing US stand-alone fund to accommodate institutional investor’s substantial investment. BVI tax blocker entity and availability for investment within a four-week time frame. Although this type of offering structure may typically takes 6-8 weeks, as a highly experienced and nimble law firm, we satisfied client need to - [Ress Capital](https://afundpllc.com/testimonial/ress-capital/) - Engaged by well known New York City law firm to collaborate and provide private fund expertise to a Swedish based private fund manager in connection with U.S. sub-advisory relationship to manage a reinsurance strategy for a large US alternative asset manager represented by global private fund manager law firm. - [Offshore and Onshore Offering Structure, CTA & CPO NFA Registered](https://afundpllc.com/testimonial/offshore-and-onshore-offering-structure-cta-cpo-nfa-registered/) - Client requested gap analysis for pre-existing registered CPO and CTA firm to become investor ready across offering structures for onshore-offshore investors. - [SEC, NFA, State Adviser Registration](https://afundpllc.com/testimonial/state-registration-of-investment-manager/) - We form the spectrum of exempt reporting, SEC and state registered investment advisers on federal and state level across investment and commodity trading advisers driven by each client's facts and circumstances. Alternative options and offering structure drive the analysis across SEC, state, exemptions, etc. and regulatory build out. We support clients across compliance, operations, regulatory - [Offshore Offering Structures](https://afundpllc.com/testimonial/offshore-offering-structures/) - We launch the spectrum of offshore offering structures to our clients attracting both US and offshore investors streamlining the process across the spectrum of strategies and offering structures on a viable basis applying our years or experience, expertise and offshore relationships. - [Nikko Asset Management, New York Subsidiary](https://afundpllc.com/testimonial/nikko-asset-management/) - For a global asset management managing the largest fixed income strategies in Asia, our Managing Partner executed the strategy and spectrum of offshore structures, teams and people to provide both strategic and execution support to client's CEO and CIO across a global best practices infrastructure of fund formation, compliance framework, operational risk management, legal and - [Onshore & Offshore British Virgin Islands Segregated Series Structure](https://afundpllc.com/testimonial/onshore-offshore-british-virgin-islands-segregated-series-structure/) - For US hedge/private equity hybrid manager reorganized BVI segregated series structure to increase operational and legal efficiencies and transfer of US and offshore assets into new BVI master-feeder structure to improve economic and legal efficiencies. - [US Parallel Fund](https://afundpllc.com/testimonial/closed-end-fund-us-parallel-fund/) - For pioneer portfolio manager launching to support master - feeder structure, a stand alone fund driven by tax and risk management issues, a key consideration when launching a new strategy. This strategy will invest in mutual funds with a focus on equities under a successful quantitative strategy. - [US & Offshore Commercial Loan Origination Real Estate Offerings](https://afundpllc.com/testimonial/real-estate-fund/) - For US commercial real estate fund, executed multi-layered offshore and onshore master feeder structure and reorganized existing investment manager organization from segregated series platform to its own master-feeder structure. Prepared robust offering memoranda and structure for client organization to mitigate cost and facilitate independent offerings to its US and offshore investors. - [Consistent Capital LP](https://afundpllc.com/testimonial/commodity-trading-adviser-pool-registered-with-the-nfa/) - Texas based Commodity Trading Adviser & Pool Registered with the NFA. For U.S. manager executed stand alone structure and filed for approval NFA compliant offering structure in connection with a managed futures strategy and framework and to offer same to Qualified Persons through its registration offering process with the NFA. - [XL Re, Bermuda Reinsurance Company](https://afundpllc.com/testimonial/kevin-peterson/) - Principal facilitated ongoing seed relationships and joint venture, investor due diligence readiness, and ultimate investments by well known re-insurance institutional investors and execution of an offshore CAT bond (insurance linked) strategy and US Investment Adviser structure to facilitate strategy and additional investments. - [Edgewood Capital Hybrid Hedge-Private Equity Strategy](https://afundpllc.com/testimonial/450/) - For well established private equity loan origination strategy and firm, engaged to collaborate with CEO to provide diagnostic review, compliance gap analysis, recommendations and execute solutions to attract assets post conversion from a conventional closed end private equity fund to an open ended hedge fund structure. - [Schneider Capital](https://afundpllc.com/testimonial/schneider-capital/) - For a well established multi-strategy private fund investment advisory firm managed by former manager of Wellington Asset Management, collaborated with CFO on firm wide gap analysis across private fund offerings & organizational framework to materially reduce legacy costs and augment solicitation strategy geared toward institutional investors for its multiple hedge fund, private equity and managed - [Guggenheim Asset Management](https://afundpllc.com/testimonial/john-dyane/) - For global Bank of Ireland ICAV structure, quarterbacked the execution of cornerstone strategy for offshore manager of managers structure across fund formation, collaborating with outside counsel, organizational and regulatory framework, sub-advisory relationship, fund manager due diligence, onboarding and operations for spectrum of US and offshore manager strategies to facilitate strategic investor, Guggenheim Asset Management. - [Aon Consulting](https://afundpllc.com/testimonial/oliver/) - Engaged by global firm AON COO Chicago subsidiary to perform diagnostic review and analysis review across execution and support of $250 Ml AUM launch of an offshore private equity fund of funds structure. - [Closed End Trading LLC](https://afundpllc.com/testimonial/closed-end-trading/) - Pioneer portfolio manager, of such firms as BNP Paribas, AQR and Magnetar Capital. Executed fund formation, corporate governance, asset raising, marketing and private fund advisor build-out and on-going support leading to the growth of its successful U.S. strategy specializing in closed end trading funds across teams and people managing assets across high net worth, family - [Anchor Risk Advisors LLC](https://afundpllc.com/testimonial/anchor-risk-advisors/) - Co-founded catastrophic bond and reinsurance onshore and offshore master-feeder and advisory firm organization to facilitate catastrophic bond and reinsurance strategy. Collaborated with re-insurance portfolio manager and well known reinsurance firm and strategic seed investor to facilitate pragmatic growth and help win institutional assets from leading Qualified Institutional Buyers with $100 million or more of net - [Argent Financial Group, Greenwich CT](https://afundpllc.com/testimonial/argent-financial/) - Formerly one of the largest traders of a convertible arbitrage strategy. Enterprise level diagnostic review, gap analysis, recommendation report in connection with a number of U.S. and offshore funds, equity funds, registered investment advisers, operations and compliance framework across its enterprise. Objective to increase efficiencies, create robust best practices infrastructure and materially reduce risk, legacy ## Categories - [pooled fund formation](https://afundpllc.com/category/our-team/afundpllc/) - [About](https://afundpllc.com/category/our-team/) - [Blog](https://afundpllc.com/category/blog/) - private fund manager focused securities law firm legal and business matter private fund expertise by both private and public sector highly experienced attorneys - [our private fund team](https://afundpllc.com/category/our-private-fund-team/) ## Category - [fund](https://afundpllc.com/Service/fund/)