Connecticut Banking Commissioner Issues Orders Relating To Investment Adviser State Registration In Response To The Dodd-Frank Act For Investment Advisers Transacting Business In Connecticut


As previously discussed in a Foley Adviser dated June 22, 2011, the Securities and Exchange Commission (the “SEC”) issued final rule releases relating to the implementation and interpretation of amendments to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), contained within the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). On July 11, 2012, the Connecticut Banking Commissioner issued two orders relating to investment adviser state registration requirements in response to the Dodd-Frank Act and the related SEC rule releases.

State Registration Time Line

The first order issued by the Banking Commissioner establishes a state registration timetable for certain investment advisers affected by the Dodd-Frank Act. In addition the order, effective July 21, 2011, repeals the Connecticut Banking Commission’s prior order (the “Prior Order”) exempting from state registration private advisers with at least $30 million in assets under management and fewer than 15 clients, as the SEC exemption for advisers with fewer than 15 clients has been repealed by the Dodd-Frank Act.

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