SEC Letter Indicates Certain Deadlines for Private Adviser Registration May Be Extended

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In an April 8, 2011 letter to the North American Securities Administrators Association, Inc. that was posted to the SEC website (available at http://www.sec.gov/rules/proposed/2010/ia-3110-letter- o-nasaa.pdf), an Associate Director of the SEC indicated that the SEC was considering providing additional time for investment advisers affected by certain provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) to come into compliance with those provisions.

According to the letter, the deadline for registration by advisers previously exempt under Section 203(b)(3) of the Advisers Act and no longer qualifying for an exemption, may be extended. The letter states that the SEC expects final rules to be issued in advance of July 21, 2011 but that an extension “may be necessary given the time needed for advisers to register and come fully into compliance with the obligations applicable to them once they are registered.”

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