There are occasions where inadvertent general solicitation may happen. If so, you may be required to “flip” your fund from a 506(b) fund to a 506(c) fund. The practical implications are:
- Investors who had closed into your fund prior to the general solicitation will not face any additional scrutiny.
- All investors who close into your fund after the general solicitation will be required to provide additional information to prove their accreditation status. We handle this closing flow on our platform for you.