Insight Venture Partners

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, CENSURE, AND DISGORGEMENT
3.
Date Initiated (MM/DD/YYYY): 
06/20/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21499
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
PRIVATE FUND
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC FOUND THAT INSIGHT CHARGED EXCESS MANAGEMENT FEES TO CERTAIN FUNDS IT MANAGES DUE TO AN INACCURATE APPLICATION OF
INSIGHTS PERMANENT IMPAIRMENT POLICY, FAILED TO DISCLOSE TO INVESTORS A CONFLICT OF INTEREST CONCERNING THAT POLICY AND DID NOT
ADOPT OR IMPLEMENT WRITTEN POLICIES OR PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT RELATING TO
THE ABOVE PRACTICES. INSIGHT DID NOT ADMIT OR DENY THE FINDINGS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
06/20/2023
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
INSIGHT WAS ORDERED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,500,000. INSIGHT PAID $1,500,000 TO THE SECURITIES AND
EXCHANGE COMMISSION ON JUNE 21, 2023. INSIGHT WAS ALSO ORDERED TO PAY DISGORGEMENT AND PRE-JUDGMENT INTEREST IN THE
AMOUNT OF $864,958.17. THAT PAYMENT WAS DEEMED SATISFIED BY PAYMENTS INSIGHT MADE IN MAY 2023 TO THE RELEVANT PRIVATE FUNDS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JUNE 20, 2023, THE SECURITIES AND EXCHANGE COMMISSION ("SEC") INITIATED A SETTLED ADMINISTRATIVE PROCEEDING AGAINST INSIGHT.
INSIGHT NEITHER ADMITTED NOR DENIED THE SEC'S FINDINGS. FROM AUGUST 2017 THROUGH APRIL 2021, THE LIMITED PARTNERSHIP AGREEMENTS
("LPAS") OF CERTAIN OF THE FUNDS INSIGHT ADVISED PROVIDED THAT INSIGHT WOULD CHARGE MANAGEMENT FEES DURING THE FUNDS' POST-

(
)
COMMITMENT PERIODS BASED ON EACH INVESTOR'S PRO RATA SHARE OF THE FUNDS' INVESTED CAPITAL, WHICH EQUALED THE ACQUISITION COST
OF THE PORTFOLIO INVESTMENTS HELD BY THE FUNDS. THE LPAS FOR THESE FUNDS ALSO STATED THAT SHOULD INSIGHT DETERMINE THAT A
PORTFOLIO INVESTMENT HAD SUFFERED A "PERMANENT IMPAIRMENT" IN VALUE, INSIGHT WOULD REMOVE AN AMOUNT EQUAL TO THE DIFFERENCE
BETWEEN THE ACQUISITION COST AND THE IMPAIRED VALUE OF THE PORTFOLIO INVESTMENT FROM THE FUND'S INVESTED CAPITAL, WHICH WOULD
SUBSEQUENTLY REDUCE THE BASIS USED TO CALCULATE THE MANAGEMENT FEES PAID BY THE RESPECTIVE FUND TO INSIGHT. INSIGHT DEVELOPED
AND APPLIED CRITERIA TO ASSESS WHETHER AN INVESTMENT WAS PERMANENTLY IMPAIRED. IN APPLYING THESE CRITERIA, HOWEVER, INSIGHT
ANALYZED PERMANENT IMPAIRMENT AT THE "PORTFOLIO COMPANY" LEVEL RATHER THAN AT THE "PORTFOLIO INVESTMENT" LEVEL. AS A RESULT, THE
SEC FOUND THAT INSIGHT DID NOT CORRECTLY APPLY THE FUNDS' LPAS IN MAKING A PERMANENT IMPAIRMENT DETERMINATION AND, CONSEQUENTLY,
FAILED TO ACCURATELY CALCULATE THE MANAGEMENT FEES IT CHARGED RESULTING IN INSIGHT CHARGING THE FUNDS EXCESS MANAGEMENT FEES
OF $773,754. FURTHER, THE SEC FOUND THAT INSIGHT FAILED TO DISCLOSE TO INVESTORS THE EXISTENCE OF A CONFLICT OF INTEREST IN
CONNECTION WITH ITS PERMANENT IMPAIRMENT CRITERIA. FINALLY, THE SEC FOUND THAT INSIGHT DID NOT ADOPT OR IMPLEMENT WRITTEN
POLICIES OR PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT RELATING TO THE ABOVE PRACTICES. AS A
RESULT, THE SEC FOUND THAT INSIGHT VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULES 206(4)-7 AND 206(4)-8
THEREUNDER. THE SEC ORDERED INSIGHT TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF
THE REFERENCED SECTIONS AND RULES, IMPOSED A CENSURE, REQUIRED DISGORGEMENT AND PRE-JUDGMENT INTEREST OF $864,958, AND IMPOSED
A CIVIL MONETARY PENALTY OF $1,500,000. AS PART OF THE RESOLUTION OF THIS MATTER, THE SEC RECOGNIZED REMEDIAL EFFORTS UNDERTAKEN
BY INSIGHT IN MAY 2021 THAT INCLUDED: ADOPTING NEW AND MORE OBJECTIVE PERMANENT IMPAIRMENT CRITERIA AND DISCLOSING THAT CRITERIA
TO INVESTORS; WAIVING ITS ABILITY GOING FORWARD TO REVERSE A PERMANENT IMPAIRMENT DUE TO CHANGED CIRCUMSTANCES; AND APPLYING
ITS REVISED PERMANENT IMPAIRMENT CRITERIA RETROACTIVELY TO FOUR PORTFOLIO COMPANIES THAT HAD BEEN IDENTIFIED BY THE SEC, LEADING
TO REIMBURSEMENT OF MANAGEMENT FEES AND INTEREST IN THE AMOUNT OF $3,821,032 TO THE RELEVANT PRIVATE FUNDS.