Vilmar Feenstra on AI Governance, Fund Documentation and Why a Correct Answer Can Still Be Legally Wrong

Vilmar Feenstra, Partner in the Investment Management practice at Loyens & Loeff in Amsterdam, joins The Agentic Allocator to discuss how AI is changing fund formation, fund documentation, and the work of the lawyers, GPs and LPs who depend on them. Vilmar advises on both sides of the table: managers raising funds and institutional investors committing to them.

His central caution is specific to legal work. Hallucination is the obvious risk. The harder one to catch is an answer that is accurate as far as it goes but incomplete from a legal perspective. Used as a starting point, AI output is valuable. Used as the final answer, it becomes a liability.

Vilmar explains why governance has to be agreed before any tool is selected, why organising data is not enough unless AI understands how fund agreements, side letters, subscription agreements and offering memoranda relate to each other, and why he expects fund documentation to start carrying explicit provisions on AI use. He also describes the fund review agent his team built, why the first version fell short, and what continued iteration produced.

What You'll Learn:

• Why an answer that is correct from an AI perspective can still be incomplete from a legal one, and why that risk is harder to spot than hallucination
• Why decisions on tools, users, sign off and permitted data have to come before tool selection
• How clear guardrails make wider experimentation across a firm possible
• Why organising data is only half the work, and why AI needs to be guided on how fund documents connect
• Why Vilmar expects LPAs and side letters to include explicit AI provisions, and why prohibiting counterparties from using AI is no longer a realistic position
• What separates the firms making progress from those that banned AI or released tools without boundaries
• Why asking staff to name their most frustrating tasks surfaces the most useful applications
• What a fund review agent that took several attempts to get right says about persistence
• A practical sequence for LPs and GPs early in adoption: governance, document context, data storage, then room to experiment

About Vilmar Feenstra:

Vilmar Feenstra is a Partner and attorney at law in the Investment Management practice group at Loyens & Loeff in Amsterdam. He focuses on investment management structures and fund formation and works on both the GP and LP side, advising managers on the formation of their funds and institutional investors on their fund investments. His practice covers fund structuring, fund regulatory advice, and fund reviews and negotiations. Vilmar has 18 years of experience in funds law and spent time in the firm's New York office providing corporate and transactional advice. He is a member of the legal and regulatory committee of the Dutch Association of Private Equity and Venture Capital (NVP) and has been involved in building technology within the firm's funds practice, including its subscription tool for investor onboarding.

Disclaimer: This podcast is for informational purposes only and does not constitute legal advice. The views expressed are those of the speakers as of the recording date and may change over time.