Illegal Activity
none
Blackmail
none
Date
Unknown
Document Type
other
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:42
Summary
This disclosure statement outlines the compensation arrangements and potential conflicts of interest for the Solicitation Agent in referring clients to the Access Fund and Underlying Fund. It details the fees the Solicitation Agent receives and acknowledges the potential for financial incentives to influence client referrals.
Metadata
- Subject
- Disclosure Statement
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0094667
- Date
- —
Relationships 4
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Solicitation Agent | Business | Access Fund | Solicitation Agent refers clients to Access Fund and receives fees. |
| Solicitation Agent | Business | Underlying Fund | Solicitation Agent acts as placement agent for Underlying Fund. |
| Glendower GP | Business | Solicitation Agent | Glendower GP pays Solicitation Agent a placement fee. |
| Glendower Capital, LLC | Business | Solicitation Agent | Glendower Capital, LLC may pay Solicitation Agent a placement fee. |
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 for the Solicitation Agent.
Financial Information
Amounts:$3 million$5 million0.4875%0.36%0.05%0.20%0.75%
Assets:
- Invested Capital
- Subscriptions
Transactions:
- Servicing Fee based on Subscription amount
- Placement fee equal to 0.75% of Access Fund's capital commitment to Underlying Fund
Legal Compliance
- Potential conflict of interest due to financial incentives for the Solicitation Agent to refer clients to the Access Fund.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealingsLegal matters/litigation
People 1
Organizations 6
Glendower GPAccess FundGlendower Capital, LLCUnderlying FundiCapitalSolicitation Agent
Text Analysis
- Tone
- Informative
- Purpose
- To disclose the compensation arrangements and potential conflicts of interest related to the Solicitation Agent's involvement with the Access Fund and Underlying Fund.
- Significance
- This document outlines the financial incentives and potential conflicts of interest for the Solicitation Agent, which is important for investors to understand.
File Info
- File Name
- EFTA01390236.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:42:32.704025
- DOJ Source
- View on DOJ