SEC Releases New Rule on Family Offices for IA Registration Exclusion The Dodd-Frank Act created a new “family office” exclusion from the definition of investment adviser because the private advisor exemption was repealed.  While Congress believed that family offices should not be subject to the SEC registration requirements, it did [...]

SEC Releases Information on Mid-Sized Advisers – New York Managers may be Required to Register with SEC Currently managers with a place of business in New York are not required to register as investment advisers at the state level with the New York Department of State.  Until the Dodd-Frank Act [...]

Registration required by March 30, 2012 We are obviously a bit late on reporting that the hedge fund registration regulations were finalized by the SEC recently (see releases at end of the post).  We are not going to detail all aspects of the regulations in this post, but we will [...]

Emergency Action “Necessary” because of SEC Inaction The California Department of Corporations has provided a temporary six-month extension of Section 260.204.9 which exempts hedge fund managers from registration in California if the manager has more than $25M of AUM.  The exemption will be slightly modified to account for the changes to federal [...]

SEC Considers Whether to Adopt Registration Requirement Yesterday the SEC announced that they will conduct an Open Meeting on June 22 to determine whether to adopt the new hedge fund registration requirements and related rules. At the Open Meeting the SEC is expected to delay implementation of the regulations until [...]

Will Wait for SEC Final Registration Regulations to Propose New Rules California currently has an exemption from the registration requirements for certain fund managers with more than $25M of AUM (Rule 260.204.9).  Back in March California requested input from the investment management community on how they might change the registration [...]

Massachusetts Proposes Registration Requirement for 3(c)(1) Fund Managers As we discussed earlier in our post of state regulation of expert networks, the states are beginning to propse rules for investment advisers based on changes to the federal securities laws as a result of the Dodd-Frank Act (see California Request for [...]

In a letter to the NASAA today the SEC stated that they may extend the final deadline for IA registration under the Dodd-Frank Act.  The reason for the extension is to give companies enough time to go through the registration process once final regulations are promulgated.  The SEC stated that [...]

Focus on Growing Your Hedge Fund in 2011 On Tuesday April 5 Linedata will be sponsoring a “Cocktails and Commentary” event at the Ritz Carlton in San Francisco.  The event will begin at 3pm and will include the following panelists: Seth Blackman, Principal at Rothstein Kass Chris Grandi, President of [...]

SEC Provides Guidance on ADV Part 2 Many SEC and state registered investment advisers have completed the new Form ADV 2 as part of the annual updating amendment.*  The SEC recently published guidance with respect to certain aspects of the new form.  The question and answer style guidance deals with [...]