As we’ve discussed previously, the SEC has proposed two new exemptions from SEC registration for certain firms who would otherwise be required to register with the SEC as investment advisers: Section 203(l) (see Rule 203(l)-1) generally exempts investment advisers who only advise one or more “venture capital funds” and Section [...]

SEC Proposed Rule 203(m)-1 under Investment Advisers Act The SEC has proposed certain new rules as well as amendments to existing rules under the Investment Advisers Act as a result of the Dodd-Frank Act. New Advisers Act Section 203(m)-1 provides an exemption from registration with the SEC to those groups [...]

Proposed Rule 204-4 Pursuant to Dodd-Frank Act The SEC has proposed certain new rules as well as amendments to existing rules under the Investment Advisers Act as a result of the Dodd-Frank Act.  The following proposed new rule 204-4 provides that certain “exempt reporting advisers” are required to file Form [...]

Proposed Rule 203A-5 Pursuant to Dodd-Frank Act The SEC has proposed certain new rules as well as amendments to existing rules under the Investment Advisers Act as a result of the Dodd-Frank Act.  The following proposed new rule 203A-5 provides that (i) SEC registered investment advisers must report their AUM [...]

Proposed Rule 203A-1 Pursuant to Dodd-Frank Act The SEC has proposed certain new rules as well as amendments to existing rules under the Investment Advisers Act as a result of the Dodd-Frank Act.  The following proposed new rule 203A-1 will replace existing Rule 203A-1.  The new rule will provide state [...]

Seeks Public Comment on Proposed Regulations On November 19, the SEC released proposed rules with respect to the new hedge fund registration requirement under the Dodd-Frank act.  The major proposals include the following: Rules with respect to the manner and process of registration of hedge fund and private equity fund [...]

Timeline for Proposed & Final Manager Registration Rules Released The Dodd-Frank bill requires the SEC and CFTC to propose and promulgate final rules with respect to a number of important areas for investment managers.   As we have seen, significant time has already been devoted to trying to develop a [...]

SEC Estimates Preparation Costs of $3,000 to $5,000 for SEC Registered Advisers We have been reviewing the SEC release related to the amendments to Form ADV Part 2.  Specifically we were interested, like many managers, in the amount of time it will likely take to complete the new Part 2. [...]

A couple of weeks ago the SEC announced that they approved certain updates for Form ADV Part 2 .  While these forms will be required for managers who are subject to registration with the SEC (under the new rules, those managers with either $100 or $150 million of assets under [...]

New Form to Require More Disclosure On July 21, the SEC approved changes to the Form ADV Part II which are designed to provide more and better information to investors.  Currently Part II (and Schedule F which qualifies much of the information on Part II) contains a series of check [...]