Investment Allocation Policy Template for Private Fund Advisers
Advisers Act Section 206 and Rule 206(4)-8
How investment opportunities are divided among funds and accounts, who gets co-investment and on what basis, and how exceptions are approved and recorded.
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What the rule requires
An adviser that manages more than one fund or account must allocate investment opportunities fairly and in line with what it has told clients and investors. Its fiduciary duty and Rule 206(4)-8 reach allocations that favour one client, a fund with higher fees, or the adviser's own accounts.
The 2023 private fund adviser rules that would have added specific requirements were vacated in 2024, so these duties rest on the Advisers Act itself. Allocation remains an examination priority.
What the policy covers
The sections of Luna's model Allocation of Investment Opportunities policy. Your draft includes only the clauses that apply to your firm.
- 1Purpose and governing principles
- 2Allocation among funds
- 3Co-investment
- 4Exceptions and conflicts
- 5Disclosure, records and review
What Luna asks you
A few of the questions that shape the draft:
- Whether the firm manages more than one fund or account
- Whether investors or others co-invest alongside the funds
- The factors used to decide an allocation
- Who approves an exception
How drafting works
- 01Answer questions about your firm
Plain questions about how you operate. Where there is a common answer, Luna suggests it; where you are not sure, say so and it is flagged rather than assumed.
- 02Luna drafts the policy
Only the clauses that apply to your firm, in your firm's name, each traced to the rule or choice it comes from.
- 03Review what is left
Anything unanswered is marked in the text and listed for you, and the policy cannot be approved until each is settled.
- 04Edit, approve and roll out
It is your policy: edit it like any other, approve it, and have employees acknowledge it in the same place.
Read the source
Other policies
A summary of what the rule requires, current as of October 2026, so you can see what the policy covers. It is not legal advice. A policy drafted in Luna is your firm's draft to review, edit and adopt.