SEC’s Corp Fin Suggests Disclosure Relevant for Closed-End and Private Equity Funds
The SEC’s Division of Corporation Finance has issued a disclosure letter for structured note offerings, which may be relevant for closed-end funds and private equity funds. The letter requires prominent disclosure about differences between a security’s offering price and the issuer’s estimate of fair value. The staff also requests disclosure about different uses of value on account statements or repurchase offers. The letter also requests disclosure about limitations on secondary market liquidity and the use of hypothetical historical price information.