SEC Adopts Final Dodd-Frank Amendment Rules Regarding Registration of Investment Advisers


The Securities and Exchange Commission (“SEC”) on June 22, 2011 adopted three sets of rules, rule amendments and Form ADV amendments under the Investment Advisers Act of 1940 (“Advisers Act”) to implement provisions of Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) regarding the registration of investment advisers with the SEC. The SEC proposed the exemption and implementation rules in November 2010.1 Each of these rules, except for the exemption for advisers to venture capital funds, has been adopted in substantially the same form as previously proposed by the SEC. In addition, the SEC adopted the “family office” rule, which defines those “family offices” that would be excluded from the definition of investment adviser under the Advisers Act and, thus, would not be subject to regulation under the Advisers Act.2

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