Finn Dixon & Herling LLP

SEC Proposes Rules to Implement New Investment Adviser Registration Requirements Mandated by Dodd-Frank Act

On November 19, 2010, the SEC issued rule proposals that would implement provisions of the Dodd-Frank Act. Among other things, the proposed rules would:

  • Facilitate registration of advisers to hedge funds, private equity funds and other private funds with the SEC.
  • Implement the Dodd-Frank Act's mandate to require reporting by certain advisers that are exempt from SEC registration.
  • Increase the asset threshold for advisers to register with the SEC.
  • Define "venture capital fund" and provide clarity regarding certain exemptions to investment adviser registration.
  • Require disclosure of greater information by investment advisers and the private funds they manage.

SEC Release no. IA-3110 can be found on the SEC’s web site at: http://www.sec.gov/rules/proposed/2010/ia-3110.pdf

SEC Release no. IA-3111 can be found on the SEC’s web site at: http://www.sec.gov/rules/proposed/2010/ia-3111.pdf

The SEC is seeking comments during the 45-day period immediately following the publication of the releases in the Federal Register.