Illegal Activity
none
Blackmail
none
Date
Unknown
Document Type
other
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:42
Summary
This document is a disclosure statement outlining the compensation arrangements and potential conflicts of interest for a Solicitation Agent referring clients to the Access Fund and Underlying Fund. The Solicitation Agent receives servicing and placement fees, which creates a financial incentive to refer clients to these specific funds.
Metadata
- Subject
- Georgetown University Endowment Servicing Fee
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0093801, SDNY GM_00239985
- Date
- —
Relationships 5
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Solicitation Agent | business | Access Fund | Solicitation Agent refers clients to Access Fund and receives servicing fees. |
| Solicitation Agent | business | Underlying Fund | Solicitation Agent acts as placement agent for Underlying Fund and receives placement fees. |
| Glendower GP | business | Solicitation Agent | Glendower GP pays the Solicitation Agent a placement fee. |
| Glendower Capital, LLC | business | Solicitation Agent | Glendower Capital, LLC may pay the Solicitation Agent a placement fee. |
| Access Fund | business | iCapital | iCapital is involved in the compensation arrangements with the Solicitation Agent. |
Notable Quotes 2
Given the existence of the compensation arrangements described above, the Solicitation Agent may benefit financially from referring clients to an Access Fund rather than to other competitive funds or other products that may also be appropriate for particular clients.
As a result, the Solicitation Agent's receipt of such payments from the iCapital creates a potential conflict of interest in the form of an additional financial incentive to the Solicitation Agent, its equity owners and investment representatives to refer clients to an Access Fund.
Red Flags 1
- Potential conflict of interest due to the Solicitation Agent's financial incentive to refer clients to specific funds.
Financial Information
Amounts:$3 million$5 million0.4875%0.36%0.05%0.20%0.75%
Assets:
- Access Fund's Invested Capital
- Access Fund's aggregate capital commitment to the Underlying Fund
Transactions:
- Servicing fee paid to Solicitation Agent based on DB Introduced Person's allocable share of Access Fund's Invested Capital.
- Placement fee paid to Solicitation Agent by Glendower GP or an affiliate based on Access Fund's aggregate capital commitment to the Underlying Fund attributable to DB Introduced Person subscriptions.
Legal Compliance
- Potential conflict of interest due to the Solicitation Agent benefiting financially from referring clients to an Access Fund.
Raw Analysis JSON
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Themes
Financial transactions/money flowBusiness dealingsLegal matters/litigation
Organizations 7
Georgetown University EndowmentAccess FundGlendower GPGlendower Capital, LLCUnderlying FundSolicitation AgentiCapital
Text Analysis
- Tone
- Informative, Disclosure
- Purpose
- To disclose the compensation arrangements and potential conflicts of interest related to the Solicitation Agent referring clients to the Access Fund and Underlying Fund.
- Significance
- This document outlines the financial incentives for the Solicitation Agent and discloses potential conflicts of interest, which is important for investors to understand.
File Info
- File Name
- EFTA01389442.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:42:37.444152
- DOJ Source
- View on DOJ