MFDF Publishes Four-Part 15(c) White Paper

Throughout 2025, MFDF (in collaboration with Morgan Lewis) published in four parts practical guidance for fund independent directors on board oversight of advisory agreement renewals. These four parts are now combined into a single document.  The paper explores the following areas of the 15(c) process, each of which is also available as a stand-alone piece:

• Part 1: Regulatory Requirements and Judicial Caselaw
• Part 2: Board Processes
• Part 3: Gartenberg Factor Analysis and Board Considerations
• Part 4: Enforcement Action Takeaways
  

Taken together, the four parts of MFDF’s 15(c) White Paper are intended to be a working tool for independent directors navigating the realities of advisory agreement review.

Click here to view the consolidated MFDF 15(c) White Paper.