Shelter in Place/ Stay at Home Order by State

The SEC’s proposed increase to qualified client thresholds, raising the bar to $1.4 million in assets under management and $2.7 million in net worth, may look like a routine inflation adjustment. It isn’t. For fund managers, it’s a structural shift that directly narrows the pool of investors eligible for performance-based compensation, including carried interest, incentive allocations, and performance fees. Emerging managers, growth-stage sponsors, and funds reliant on high-net-worth individuals near the current threshold will feel the friction first, and those who wait to adapt will feel it most in their next raise.