SEC Issues Rule Proposals to Implement Dodd-Frank for Investment Advisers


On Nov. 19, 2010, the Securities and Exchange Commission issued two separate releases under the Investment Advisers Act of 1940 to implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The first release described in this briefing, Advisers Act Release IA-3110, includes rules and rule amendments that are designed to give effect to provisions of the Dodd-Frank Act that, among other things, would increase the statutory threshold for registration by investment advisers with the SEC from $25 million to $100 million, would require advisers

to many hedge funds and other private funds to register with the SEC, and would require SEC reporting by certain investment advisers that are exempt from registration. The second release

described in this briefing, Advisers Act Release IA-3111, includes rules that would implement new exemptions from the registration requirements of the Advisers Act for advisers to certain privately offered investment funds that were enacted as part of the Dodd-

Frank Act.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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