The Investment Advisers Act of 1940 (the “Advisers Act”) is a relatively compact statute, and for many years the Securities and Exchange Commission (SEC) adopted relatively few regulations specifically targeting Advisers Act compliance. This has changed quite dramatically in recent years, as registered advisers and even firms relying on registration exemptions are increasingly subject to highly specific and at times complex rules, interpretations and other guidance issued by the SEC and its Staff in the Division of Investment Management (IM) and the Division of Exams (EXAMS).