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Recognized as one of the most active and highly regarded investment management practices in the United States, our group represents all types of asset managers across the liquidity spectrum, including private equity funds, credit funds, hedge funds, venture capital funds, real estate funds, hybrid funds and family offices. We have successfully raised hundreds of billions of dollars for our clients, who benefit from our extensive market knowledge, industry-leading networking events and strong relationships with all major market participants.
December 21, 2015 download PDF
- the financial institution does not share nonpublic personal information with nonaffiliated third parties (other than as permitted under certain enumerated exceptions, e.g., to service providers who perform services on behalf of the financial institution, or as necessary to administer a transaction requested or authorized by an individual); and
- the financial institution has not changed its privacy policies and practices from the policies and practices that were disclosed in the most recent privacy notice sent to individuals.
 FAST ACT (see, Title LXXV, Section 75001. Eliminate Privacy Notice Confusion).
 §505 of the GLBA charges various regulators with adopting rules and regulations implementing the privacy provisions contained in Title V of the GLBA. The Securities Exchange Commission adopted Regulation S-P applicable to registered investment advisers. The Federal Trade Commission adopted Regulation Part 313 applicable to financial institutions that are not subject to the jurisdiction of a specific agency (thus, picking up private funds).
 Pursuant to §509 of the GLBA, a "consumer" or a "customer" must be an individual. Therefore, an investor in a private fund that is not an individual, such as a pension plan, is neither a consumer nor a customer of the investment adviser or private fund. Neither the investment adviser nor the private fund is required to provide a privacy notice to any such investor, although in practice, many investment advisers and private funds provide privacy notices to all investors.