On June 23, 2011, the Securities Exchange Commission (“SEC”) promulgated Final Rule 275.202(a)(11)(G)-1 (“Final Rule”) defining the term “family offices” for purposes of excluding certain family offices from the registration requirements of the Investment Advisers Act of 1940 (“Advisers Act”) as amended last July by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).
The Dodd-Frank Act repealed the private adviser exemption under Section 203(b)(3) of the Advisers Act which most family offices had previously relied upon to avoid registration. Family offices were hoping to rely upon a new exemption for “family offices” under the Dodd-Frank Act, but were waiting on the SEC to provide further guidance as to who would qualify as a “family office.” Last year the SEC issued proposed rules that specifically excluded multi-family offices from the definition of a family office and very narrowly defined the term family office.
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