On November 19, 2010, the U.S. Securities and Exchange Commission (the "SEC") issued proposed rules, pursuant to title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). The proposed rules would clarify and implement three new exemptions created under the Dodd-Frank Act for advisers to venture capital funds, private fund advisers with less than $150 million in assets under management in the United States and certain foreign private advisers. These new limited exemptions would replace portions of the former statutory exemption for limited advisors—those with fewer than 15 clients—which were removed by the Dodd-Frank Act. The proposed rules would also implement expanded disclosure and registration requirements set forth in the Dodd-Frank Act for advisers to hedge funds and other private funds. This Alert provides a brief summary of the proposed rules. For a more detailed explanation of the new registration requirements enacted under the Dodd-Frank Act, please see our earlier Alert, "Registration of Advisors to Private Investment Funds and Pools, and of Small Advisory Firms."
Please see full alert below for more information.
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