The “Liberation Day” tariffs and associated countermeasures have created significant market volatility, prompting renewed scrutiny of private fund managers’ compliance with longstanding SEC focus areas such as valuation, investor communications, liquidity, borrowing and related disclosures. Sponsors should document any changes to valuation practices, maintain transparent and timely communications with investors about strategy shifts, and ensure that measures like liquidity restrictions or leverage activities are fully aligned with fund documents and previous disclosures. While the tariffs are new, regulators’ fundamental compliance expectations are not.
