Statement Summary
The Securities and Exchange Commission (SEC) has announced an application from Adams Street Private Equity Navigator Fund LLC and Adams Street Advisors, LLC, requesting exemptions under the Investment Company Act of 1940. The applicants seek permission for certain registered closed-end investment companies to:
- Issue multiple classes of shares
- Introduce early withdrawal charges
- Implement asset-based distribution and service fees
Filed on April 1, 2025, the SEC will grant the order unless a hearing is requested by interested parties by June 2, 2025, by contacting the SEC’s Secretary. Further details are available through the SEC’s EDGAR system or by contacting its Office of Investor Education and Advocacy.
Original Statement
SECURITIES AND EXCHANGE COMMISSION
Investment Company Act Release No. 35577; 812-15740
Adams Street Private Equity Navigator Fund LLC and Adams Street Advisors, LLC.
May 7, 2025.
AGENCY: Securities and Exchange Commission (“Commission” or “SEC”).
ACTION: Notice.
Notice of an application for an order pursuant to section 6(c) of the Investment Company Act of 1940 (the “Act”) for an exemption from sections 18(a)(2), 18(c), and 18(i) of the Act, pursuant to sections 6(c) and 23(c) of the Act for an exemption from rule 23c-3 under the Act, and pursuant to section 17(d) of the Act and rule 17d-1 thereunder.
Summary of Application
Applicants request an order to permit certain registered closed-end investment companies to issue multiple classes of shares and to impose early withdrawal charges and asset-based distribution and/or service fees.
Applicants: Adams Street Private Equity Navigator Fund LLC and Adams Street Advisors, LLC
Filing Date: The application was filed on April 1, 2025.
Hearing or Notification of Hearing: An order granting the requested relief will be issued unless the Commission orders a hearing. Interested persons may request a hearing on any application by e-mailing the SEC’s Secretary at Secretarys-Office and serving the Applicants with a copy of the request by e-mail, if an e-mail address is listed for the relevant Applicant below, or personally or by mail, if a physical address is listed for the relevant Applicant below.
Hearing requests should be received by the Commission by 5:30 p.m. on June 2, 2025, and should be accompanied by proof of service on the Applicants, in the form of an affidavit, or, for lawyers, a certificate of service. Pursuant to rule 0-5 under the Act, hearing requests should state the nature of the writer’s interest, any facts bearing upon the desirability of a hearing on the matter, the reason for the request, and the issues contested. Persons who wish to be notified of a hearing may request notification by emailing the Commission’s Secretary.
Addresses
The Commission: Secretarys-Office
Applicants: Eric R. Mansell, Adams Street Advisors, LLC, emansell, with copies to Nicole M. Runyan, P.C., Kirkland & Ellis LLP, nicole.runyan and Brad A. Green, P.C., Kirkland & Ellis LLP, brad.green
For Further Information Contact
Trace W. Rakestraw, Senior Special Counsel, at (202) 551-6825 (Division of Investment Management, Chief Counsel’s Office).
Supplementary Information
For Applicants’ representations, legal analysis, and conditions, please refer to Applicants’ application, dated April 1, 2025, which may be obtained via the Commission’s website by searching for the file number at the top of this document, or for an Applicant using the Company name search field on the SEC’s EDGAR system. The SEC’s EDGAR system may be searched at You may also call the SEC’s Office of Investor Education and Advocacy at (202) 551-8090.
For the Commission, by the Division of Investment Management, under delegated authority.
Sherry R. Haywood, Assistant Secretary.
