Loon Creek Capital Data Retention Policy
Effective Date: April 18, 2025

​

1. Purpose & Scope

 

Loon Creek Capital Group, LLC ("Loon Creek") is committed to managing client data in compliance with applicable tax regulations and legal requirements. This Data Retention Policy establishes the retention and deletion guidelines for client records, specifically for:

• Clients whose deals fail to close.

• Clients who are terminated.

• Clients whose deals exit.

​

This policy applies to all physical and electronic records, including but not limited to LLC formation documents, investor agreements, investment documents, and related communications.

​

2. Regulatory & Compliance Considerations

​

Loon Creek follows the retention requirements set forth by the Internal Revenue Service (IRS), Securities and Exchange Commission (SEC), state regulations, and other applicable financial laws. Key considerations include:

• The IRS requires tax-related records to be retained for a minimum of seven (7) years from the final tax year associated with the investment.

• SEC and financial regulations may impose additional retention requirements based on SPV & fund administration services.

• State laws govern LLC record retention, dissolution procedures, and inactive entity filings.

​

3. Document Retention Periods

The following table outlines the retention periods for different types of client records:

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

 

​

​​​​

Important Notes on Retention Categories:

​

• Exited Deals: For clients whose SPVs reach an exit (via liquidity event or dissolution), records will be retained in accordance with the 7-year retention period noted above.

• Terminated Clients (Pre-Exit/Dissolution): If Loon Creek terminates services for a client prior to a deal closing, exiting, or dissolving, we will not retain records beyond termination. A shared Google folder containing all relevant documents will be provided to the manager for a limited time. Once access to the folder expires, the records will be permanently deleted, and Loon Creek will assume no further responsibility for them following termination.

• Failed-to-Close Deals: For SPVs that do not close and never become active, no records are retained. Related files and information are deleted upon determination that the deal did not proceed.

​

4. Data Disposal & Secure Destruction

Loon Creek is committed to protecting client confidentiality when deleting records. The following procedures apply:

• Physical records: Secure shredding and disposal.

• Electronic records: Permanent deletion from systems.

• Legal holds: No data will be destroyed if under audit, litigation, or regulatory review.

​

5. Client Notification & Exceptions

• Clients may be informed of Loon Creek’s data retention policies upon deal failure, termination, or successful exit.

• Exceptions to this policy apply if records are required for ongoing audits, litigation, or regulatory inquiries.

​

6. Policy Review & Updates

This policy will be reviewed annually and updated as necessary to comply with evolving regulatory requirements and business needs.

For questions regarding this policy, please contact us at info@looncreekcapital.com