Exemptions › Investment Adviser

CFTC 4.13(a)(3) Annual Affirmations Due by March 1st

As a reminder, fund managers relying on the exemption from registration with the U.S. Commodity Futures Trading Commission (the "CFTC") set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more

Massachusetts Securities Division Sending Letters Requiring Documentation from MA Exempt Reporting Advisers

The Massachusetts Securities Division ("the Division") is currently sending letters to exempt reporting advisers in Massachusetts ("MA ERAs") who manage private funds which rely on the exclusion from the definition of...more

What exactly does being exempt from Investment Adviser registration under Dodd-Frank mean?

It is widely known that under the Dodd-Frank Act passed last year, private fund managers with assets under management of $150 million or more will be required to register as investment advisers with the SEC. It's also widely...more

Dodd-Frank Act Update: SEC Proposes Rules Applicable to Investment Advisers

On November 19, 2010, the U.S. Securities and Exchange Commission (the "SEC") issued proposed rules, pursuant to title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). The proposed...more