SEC Advisory

SEC proposes new rules and rule amendments implementing the investment advisor provisions of the Dodd-Frank Act. 

This advisory discusses several new proposed SEC rules and rule amendments (the “Proposed Rules”) that implement various provisions of Title IV of the Dodd- Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). Included among the Proposed Rules are provisions that (1) increase the statutory threshold for investment adviser registration with the SEC; (2) require advisers to hedge funds and other private funds to register with the SEC; (3) require reporting by certain investment advisers that are exempt from registration; (4) amend the “pay-to-play rule” as it relates to regulated municipal advisers; and (5) implement new exemptions from the registration requirements of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) for certain advisers.  The comment period for the Proposed Rules will remain open until January 24, 2011.

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