SEC Contemplates Extending Registration Deadlines for Investment Advisers

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In a letter dated April 8, 2011 to the President of the North American Securities Administrators Association, Inc., Robert E. Plaze, Associate Director of the Securities and Exchange Commission (“SEC”), indicated that the SEC will consider extending the deadlines by which certain advisers must register with the SEC, or switch from SEC to state registration, under the new provisions of the Dodd-Frank Wall Street Reform and Consumer Protect Act (the “Dodd-Frank Act”).

Under the Dodd-Frank Act, mid-size advisers having between $25 and $100 million in assets under management will generally have to withdraw their SEC registration and re-register under state securities laws. Plaze indicated that changes to the Investment Adviser Registration Depository system (IARD) necessary to facilitate this transition will take until the end of 2011 to complete, and that as a result, he expects the SEC to extend the date for mid-sized advisers to make this transition to state registration to the first quarter of 2012.

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