Thailand's SEC Tightens Private Fund Disclosure Rules
Thailand's Securities and Exchange Commission tightened private fund disclosure rules effective July 16, requiring enhanced transparency in performance reporting, customized investor statements, and stricter conflict-of-interest management.
The Securities and Exchange Commission (SEC) has upgraded private fund regulations to improve transparency and investor reporting standards, effective July 16, 2025. The revisions cover disclosure requirements for standard portfolio private funds (PFS), individualized investment status reporting tailored to investor profiles, and explicit conflict-of-interest (COI) management protocols.
The updated rules maintain investor protections by ensuring sufficient information for sound investment decisions while avoiding excessive compliance costs for fund operators. The SEC held public comment periods from November–December 2024 and April–May 2025, during which most stakeholders endorsed the proposed framework. Key improvements include: (1) Enhanced clarity in PFS disclosures, requiring that fund managers not cherry-pick favorable performance periods for marketing and must present past results transparently and representatively; (2) Flexible reporting formats for private fund investment status, allowing customization by investor type and service model while maintaining necessary tracking information; and (3) Strengthened COI management guidelines aligned with mutual fund standards, covering cross-trades between funds or clients under the same management, and mandatory disclosure of compensation or benefits that could create conflicts of interest.
Two related announcements were published in the Government Gazette and became effective July 16, 2025: SEC Notice No. 7/2569 on criteria and procedures for managing non-pension private funds (Revision 2), and Practice Guideline Notice No. 3/2569 on conflict-of-interest policies and systems for fund managers.
