Illegal Activity
suspicious
Blackmail
none
Date
April 2018
Document Type
Supplement to Confidential Private Placement Memorandum
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This document is a supplement to a private placement memorandum for Glendower Access Secondary Opportunities IV (U.S.), L.P., focusing on the role and compensation of Deutsche Bank Securities Inc. as a placement agent. It outlines the fees paid to Deutsche Bank by investors and the fund, and discloses potential conflicts of interest arising from these arrangements and past regulatory settlements.
Metadata
- Subject
- GLENDOWER ACCESS SECONDARY OPPORTUNITIES IV (U.S.), L.P. AN "ACCESS FUND" INTO GLENDOWER CAPITAL SECONDARY OPPORTUNITIES FUND IV, LP (For Investors referred by Deutsche Bank Securities Inc.) OFFERING OF LIMITED PARTNER INTERESTS
- Sender
- —
- Recipients
- —
- Document ID
- GLDUS133
- Date
- April 2018
Illegal Activity
- Severity
- suspicious
- Description
- The document mentions past regulatory settlements involving DBSI 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. This is a disclosure of past legal issues, not evidence of ongoing illegal activity by the sender.
- Content Type
- court_document
Relationships 5
| 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 Fund. |
| Deutsche Bank | Servicing | DB Introduced Person | The Investment Manager will pay Deutsche Bank a Servicing Fee in respect of each DB Introduced Person. |
| DB Introduced Person | Payment | Deutsche Bank | Each DB Introduced Person will directly pay Deutsche Bank a Placement Fee. |
| Glendower GP or an affiliate | Payment | Deutsche Bank | Glendower GP or an affiliate shall pay Deutsche Bank a placement fee equal to 0.75% of the portion of the Access Fund's aggregate capital commitment to the Underlying Fund attributable to the Subscriptions of each DB Introduced Person. |
Notable Quotes 2
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.
Accordingly, the potential for Deutsche Bank to receive such fees in connection with the Access Funds may create an incentive for Deutsche Bank to recommend and market an investment into the Access Funds and presents a potential conflict of interest in recommending a direct or indirect investment in the Access Funds as compared to investments in other funds where Deutsche Bank may not receive such fees or may receive lower fees.
Red Flags 2
- The varying fee structures and potential for Deutsche Bank to waive or reduce fees for certain investors, creating potential for unequal treatment.
- The potential conflicts of interest arising from Deutsche Bank's multiple roles and compensation streams.
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 Partner Interests in Glendower Access Secondary Opportunities IV (U.S.), L.P.
- Assets of Glendower Access Secondary Opportunities IV (U.S.), L.P.
Transactions:
- Payment of Servicing Fee by Investment Manager to Deutsche Bank
- Payment of DB Placement Fee by DB Introduced Person to Deutsche Bank
- Payment of placement fee by Glendower GP or an affiliate to Deutsche Bank
Public Knowledge
- Context
- The document details the financial arrangements and potential conflicts of interest related to a private equity fund offering, which could be of interest to financial journalists and investors.
- Media Worthy
- Yes
Legal Compliance
- Potential conflicts of interest due to Deutsche Bank receiving fees from multiple parties (DB Introduced Persons, Investment Manager, Glendower GP).
- Disclosure of past regulatory settlements involving DBSI 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/litigationAllegations/complaintsPolitical connections/influence
Organizations 14
Georgetown University EndowmentGlendower 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.U.S. Internal Revenue ServiceGlendower GPGlendower Capital, LLCSECNational Association of Securities DealersNew York Stock ExchangeNew York Attorney GeneralNew Jersey Department of Securities
Locations 3
U.S.EnglishNew York
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 compensation structure for Deutsche Bank Securities Inc. as a placement agent for the Glendower Access Secondary Opportunities IV (U.S.), L.P. fund, and discloses potential conflicts of interest.
File Info
- File Name
- EFTA01439443.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:27.547233
- DOJ Source
- View on DOJ