“Most” Does Not Mean All

Because the Dodd-Frank Act requires the adoption of so many new regulations, I like to say that the other shoe (or more likely a whole closet full of shoes) remains to be dropped. One large shoe that is yet to be dropped is how the Securities and Exchange Commission will define “venture capital fund” for purposes of the exemption from the Investment Advisers Act mandated by the Dodd-Frank Act. The comment period on the SEC’s proposed definition of “venture capital fund” ended yesterday.

As I mentioned in yesterday’s post, the California Commissioner of Corporations, Preston DuFauchard, has submitted a comment letter expressing concerns about the narrowness of the SEC’s proposed definition. In my own comment letter, I take the SEC to task for its use of pseudo legislative history. For example, the SEC misleadingly invoked legislative history by...

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