On January 19, 2012, the Division of Investment Management of the Securities and Exchange Commission (the “Staff” or the “SEC”) reaffirmed its position in its December 8, 2005, response to the American Bar Association no-action letter (the “ABA Correspondence”), in which the SEC stated that, under certain conditions, special purpose vehicles (“SPVs”) would not be required to register as an investment adviser with the SEC (the “No-Action Letter”). The No-Action Letter was released in advance of the March 31, 2012, deadline to register as an investment adviser under the new requirements pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).
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