Common fund structure in real estate:

⚖️ GP: Legal control; earns carried interest; usually formed for each fund.

🏢 ManCo: Operating business w/ employees & offices. It manages the fund for a fee & lasts across multiple funds.

🏠 HoldCo: Owns assets directly (e.g., real estate).

In case you’re wondering, yes, the SEC does crack down on those who don’t timely file Form D when selling unregistered securities under Regulation D. ⚖️

Let’s say it together:

"For securities under Reg D, file Form D!"

In 2022, Investor Choice Advocates Network (ICAN) petitioned the SEC to change the “accredited investor” definition by replacing the wealth and income requirements with non-financial criteria based on knowledge and experience.

ICAN is now suing the SEC to consider the petition.

5⃣ Ongoing Customer Due Diligence

4⃣ AML/CFT Employee Training

3⃣ Designate an AML/CFT Compliance Officer

2⃣ Independent Testing of the AML/CFT Program

Critically, there are five "pillars" to an effective AML/CFT program.

I've set them out below with clippings of the actual text from the final rule:

1⃣ Internal Policies, Procedures, and Controls

Say it with me now: "Away with the CTA!"

lol now I’m down the rabbit hole of weird cycle sports and cycleball ??

Step 5: Hold the initial closing 🥂 (1 day)

The initial closing date is when you officially admit the first LPs into the fund.

Now you're ready to roll! 🚀

Funds generally raise money from the initial date through the next 12-18 months 👇🏿

How long does it take to raise an investment fund?

The short answer is 4-6 weeks, but there are important steps to consider. 🧵

For LPs in an investment fund, payout timing largely depends on the fund:

🔒 Closed-end funds: Fixed life, liquidate at the end, no early withdrawals.

🔓 Open-end funds: Operate indefinitely, withdrawals allowed (with limits).

Know the difference—it impacts your liquidity!

I’m curious about Bluesky’s long-term monetization plan.

For now, it seems to be selling paid services, starting with custom domains.

Unlike most social media platforms, Bluesky is philosophically opposed to selling user data for ads.

It’s an interesting departure from the ad-driven norm.

Here's a more detailed example of how the clawback works, assuming a simple European waterfall:

In this setup (standard waterfall), a clawback could apply if later investments result in losses that drop total returns below the LP’s capital + preferred return. The GP may need to return part (or all) of their $18.40 carry to ensure the LP receives their priority return.

💼 Let’s talk GP clawbacks/givebacks.
A clawback is a tool that lets investors (LPs) recover carried interest if a fund manager (GP) ends up receiving more than LPs think the GP should based on the fund’s overall performance. 🧵