What we did: 

We introduced a required attestation step for SPVs investing in another SPV or fund. Deal leads must now confirm allocation access, transferability of securities, satisfaction or waiver of transfer restrictions, required issuer consents, and the accuracy of supporting documentation. They must also acknowledge the additional risks of layered SPV structures, including fee stacking, tax complexity, reduced downstream control, and broken deal scenarios.

How it helps you:

This update increases transparency and sets clear expectations before capital is raised. It reinforces organizer accountability, reduces operational and compliance risk, and helps ensure investors are appropriately informed when participating in multi-tier SPV structures.