Subject: File No. S7-03-22
From: Anonymous
Affiliation: Private Equity Manager

April 26, 2022

From the investor perspective, definitely want less regulation as opposed to more. The idea of adding fairness opinions to all advisor led secondaries would drastically increase the expenses funds bear to transact (which would then show up in expense disclosures to investors which will probably make them scratch their heads as to why it costs so much to simply transact in the private markets). Providers of FOs also get sued almost every time they issue one and some institutions simply dont offer them anymore. The cost of getting sued also factors into the price they charge which has caused the cost of a FO to balloon over time.

GPs typically like to be more aggressive marking up funds / investments when fundraising and more conservative when marking down losers. When not in fundraising mode, they typically like to be more conservative marking up winners so that there is more of a surprise to the upside factor when the business actually exits. Theres good incentives for deal leads to not be overly aggressive in marking up investments as well since marking down a previously aggressively marked up investment reflects poorly on your book.

I think investors would generally prefer a market based approach to valuing their portfolios. Latest comparable transaction, trading comps, etc. as much preferred over FO type work which is very heavy handed.