Chapter 10

The Final Close Checklist

A comprehensive guide to executing a smooth fund closing, covering the six weeks before close through post-close stabilization.

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7 sections

This chapter provides a comprehensive guide to executing a smooth fund closing, covering the six weeks before close through post-close stabilization. Institutional closing requires coordinated execution across legal, operations, compliance, and banking functions.

6-Week Pre-Close Countdown

Week -6 to -4: Preparation Phase

  • Finalize LPA (fees, carry, catch-up, governance, expenses)
  • Finalize PPM as single source of truth
  • Complete subscription templates with e-signature
  • Confirm fund admin close-ready (SOW signed, portal provisioned)
  • Open fund operating and sweep accounts

Week -3 to -1: Final Execution

  • Circulate finals with 7-10 day review window
  • Distribute AML/KYC packages
  • Confirm capital call amounts and test wires
  • Schedule LP closing call

Week 0: Close Execution

  • Send capital call notices
  • Collect executed subscriptions
  • Final AML/KYC verification and sanctions screening
  • Monitor and reconcile wires
  • File Form D on EDGAR within 15 days
  • State EFD notices

Banking & Capital Call Mechanics

Fund Operating Account

Dedicated account with dual-approval, role-based access. Never commingle with GP or personal funds.

Capital-Call Sweep Account

Separate inbound-only account with standardized wire narratives for LP contributions.

Capital-Call Line

Subscription line bridging timing between commitments and deployments. Document borrowing-base.

Governance Framework

Facility caps 25-50% of commitments. Treasury Controls Checklist required.

AML/KYC Procedures

Note: FinCEN investment-adviser rule effective January 1, 2028 — build policies now

Core Requirements

Risk assessment and written policies
Staff training program
Independent testing schedule

Collection Requirements

Individuals

  • Name and address
  • Date of birth
  • Government-issued ID

Entities

  • Formation documents
  • Directors/officers
  • LEI (if applicable)

Screening Requirements

OFAC, UK HMT, EU sanctions lists
Politically Exposed Persons (PEP) screening
Adverse media screening

Record Retention & Vendors

  • 5 years post-relationship retention requirement
  • Recommended vendors: Vestlane, Cascade, KYC-Chain
  • Require SOC 2 Type II certification from vendors

Post-Close Operations (Day 1-30)

  • Finalize cap table and capital accounts
  • Provision LP portal with ILPA v2.0 guide
  • Execute first capital call
  • Hold IC meeting on deployment
  • File Form D, archive books/records

Common Closing Mistakes

Premature closing before pipeline ready

Incomplete AML/KYC

Mismatched sweep mechanics

Unclear MFN/side-letter policy

Poor LP communication

Key Takeaway: Institutional closing requires coordinated execution across legal, operations, compliance, and banking functions, with clear documentation and communication throughout.