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Waterfalls

When should waterfall terms be reviewed by counsel before distributions?

By Michael Kaufman

Counsel should review when terms are ambiguous, side letters affect payments, reserves are discretionary, clawback risk exists, or material carry will be paid.1,2

Legal review is most useful before money moves, when ambiguity can still be resolved through process and documentation. For sponsors, LP finance teams, administrators, and counsel reviewing distribution economics, the practical answer is to treat the question as part of distribution modeling, return thresholds, preferred return, catch-up, promote, reserves, true-up, and clawback review, not as a one-off definition. The record should show the governing agreement, proceeds schedule, capital accounts, waterfall model, reserve analysis, distribution notice, and approval record so an investor, lender, counsel, administrator, or operating lead can reconstruct the decision later. Ask counsel to review the distribution sequence, defined terms, approval rights, notice requirements, side letters, and any discretionary reserve decision. The common failure mode is treating the model as the legal answer and discovering after payment that the documents required a different allocation or notice process.1,2

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Sources & References

  1. 1.Institutional Limited Partners AssociationCapital Call & Distribution Notice TemplateILPA(Capital call, distribution notice, LP reporting, and investor communication standards.)primary · workflow-standard · waterfalls
  2. 2.Internal Revenue ServicePartnershipsIRS(Partnership tax and reporting context for private vehicles.)primary · tax-context · waterfalls

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