The Securities and Exchange Commission (“SEC”) on June 22, 2011 adopted new rules and rule and form amendments under the Investment Advisers Act of 1940, as amended (“Advisers Act”), that are designed to imple-ment and give effect to the provisions of Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).1 Among other changes, the final rules adopted by the SEC (“Final Rules”): (i) establish new exemptions from Advisers Act registration and reporting requirements for certain advisers; (ii) extend the compliance date for registration of certain previously unregistered advisers until March 30, 2012; (iii) amend Form ADV; and (iv) reallocate regulatory responsibility for advisers between the SEC and the states.
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