Illegal Activity
suspicious
Blackmail
possible
Date
April 2018
Document Type
Memorandum Supplement
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This document is a supplement to the Confidential Private Placement Memorandum for Glendower Access Secondary Opportunities IV (U.S.), L.P., focusing on the role of Deutsche Bank Securities Inc. as a placement agent. It outlines the fees paid to Deutsche Bank, potential conflicts of interest, and past regulatory issues involving Deutsche Bank.
Metadata
- Subject
- Glendower Access Secondary Opportunities IV (U.S.), L.P. - Supplement to the Confidential Private Placement Memorandum
- Sender
- —
- Recipients
- —
- Document ID
- GLDUS127
- Date
- April 2018
Illegal Activity
- Severity
- suspicious
- Description
- The document mentions past regulatory settlements involving Deutsche Bank Securities Inc. with the SEC, the National Association of Securities Dealers, the New York Stock Exchange, the New York Attorney General, and the New Jersey Department of Securities. While these are past events, they raise concerns about the firm's compliance history.
- Content Type
- first_hand
Blackmail Indicators
- Likelihood
- possible
- Description
- The document describes a complex fee structure and potential conflicts of interest related to Deutsche Bank's role as a placement agent. While there are no explicit threats or coercion, the potential for preferential treatment or hidden fees could create leverage or pressure on investors.
Relationships 4
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Glendower Access Secondary Opportunities IV (U.S.), L.P. | Investment | Glendower Capital Secondary Opportunities Fund IV, LP | The Access Fund is expected to invest substantially all of its assets in the Underlying Fund. |
| Deutsche Bank Securities Inc. | Placement Agent | Glendower Access Secondary Opportunities IV (U.S.), L.P. | Deutsche Bank Securities Inc. acts as a Placement Agent for the Access Funds. |
| Investment Manager | Servicing Fee Agreement | Deutsche Bank | The Investment Manager pays Deutsche Bank a Servicing Fee for certain servicing functions. |
| Glendower GP | Placement Fee Agreement | Deutsche Bank | The Glendower GP pays Deutsche Bank a placement fee for clients introduced to the Underlying Fund. |
Notable Quotes 3
This supplement (the "Supplement") may only be distributed in conjunction with the Confidential Private Placement Memorandum dated January 2018 (the "Memorandum") relating to the offering of limited partnership interests (the "Interests") in Glendower Access Secondary Opportunities IV (U.S.), L.P.
Each DB Introduced Person will directly pay Deutsche Bank a Placement Fee (the "DB Placement Fee") in accordance with the schedule provided below in respect of the aggregate Subscription of such DB Introduced Person to the Access Fund.
Prospective investors should take such fees, and the related potential conflicts of interest, into account when considering and evaluating any recommendations related to a direct or indirect investment in the Underlying Fund.
Red Flags 3
- The DB Placement Fee may differ from placement fees charged to Investors introduced to the Access Funds by other Placement Agents as well as from those charged to other DB Introduced Persons.
- The DB Placement Fee may be waived or reduced by Deutsche Bank in respect of any particular DB Introduced Person without thereby entitling any other DB Introduced Person to a similar waiver or reduction.
- Deutsche Bank may or may not receive payment of similar fees (which may be lower or greater than fees received in connection with the placement of Interests in the Access Fund) with respect to the placement of interests in certain other funds established, sponsored or distributed by the General Partner, the Investment Manager, the Glendower GP or their respective affiliates, as well as others.
Financial Information
Amounts:$3 million$5 million0.65%0.45%0.05%0.4875%0.36%0.20%1.00%1.50%2.00%$20,0000.75%$87.5 million
Assets:
- Limited Partnership Interests
- Invested Capital
- Subscriptions
Transactions:
- Offering of Limited Partner Interests
- Payment of Servicing Fee to Deutsche Bank
- Payment of DB Placement Fee to Deutsche Bank
- Payment of Placement Fee to Deutsche Bank by Glendower GP
Public Knowledge
- Context
- The document details the financial arrangements and potential conflicts of interest in a private equity fund offering, which could be of interest to financial journalists and investors.
- Media Worthy
- Yes
Legal Compliance
- Potential conflicts of interest arising from Deutsche Bank's role as placement agent and the fees it receives.
- Past regulatory settlements involving Deutsche Bank Securities Inc. with the SEC, the National Association of Securities Dealers, the New York Stock Exchange, the New York Attorney General, and the New Jersey Department of Securities.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealingsLegal matters/litigationCommunications/correspondence
Organizations 13
Annandale CapitalGlendower Access Secondary Opportunities IV (U.S.), L.P.Glendower Capital Secondary Opportunities Fund IV, LPDeutsche Bank Securities Inc.Deutsche BankGlendower Access Secondary Opportunities IV (International), L.P.SECNational Association of Securities DealersNew York Stock ExchangeNew York Attorney GeneralNew Jersey Department of SecuritiesGlendower GPGlendower Capital, LLC
Locations 4
U.S.EnglishNew YorkNew Jersey
Financial Entities 2
Deutsche Bank Securities Inc.Deutsche Bank
Text Analysis
- Tone
- Professional
- Purpose
- To modify and update the Confidential Private Placement Memorandum of Glendower Access Secondary Opportunities IV (U.S.), L.P. with respect to Investors referred or introduced to the Access Fund by Deutsche Bank Securities Inc.
- Significance
- This document outlines the fees and potential conflicts of interest associated with Deutsche Bank's role as a placement agent for the Glendower Access Secondary Opportunities IV (U.S.), L.P. fund.
File Info
- File Name
- EFTA01397596.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:18.315888
- DOJ Source
- View on DOJ