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FCA 2025 review sets UK private fund valuation expectations: managing conflicts, independent governance, ad hoc triggers, consistent methodologies, third-party advisers and enhanced investor reporting

Published on: 20 May 2025

Published by a Law360 reporter
Legal News
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Article summary

This review forms part of a broader set of FCA actions in 2025 to reshape UK private funds regulation, alongside the 7 April 2025 consultation on wider regulatory reform; the 26 February 2025 ‘Dear CEO’ letter, which assessed how UK fund managers handle conflicts of interest; and the 8 May 2025 findings concerning the conduct of smaller managers (see ‘further reading’ below)

Context of FCA review

The FCA’s review arises from concerns about the distinctive characteristics of private market assets. Unlike public market assets, these holdings are not traded frequently nor subject to regular price discovery. Consequently, firms rely on judgement-led valuation techniques, creating risks such as misvaluation, conflicts of interest, or insufficient expertise. The FCA also notes that UK private fund managers operate under a range of different structures.

  • Open-ended funds, which permit redemptions throughout the fund’s life, encounter more acute valuation challenges than closed-ended funds, where genuine value and performance are only confirmed when assets are realised
  • There are also vehicles that allocate to a wide range of
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