Non-Enforcement Matters
New SEC Registrants Under Dodd-Frank to Be Focus of SEC
Examination Program
Carlo V. di Florio, Director of the SEC's Office of
Compliance Inspections and Examinations (OCIE) recently announced
the staff's intention to examine, during the next two years,
about 25 percent of the investment advisers required to register
with the SEC subsequent to the Dodd-Frank Wall Street Reform and
Consumer Protection Act of 2010 (Dodd-Frank). This group of
approximately 1,500 registrants primarily consists of investment
advisers to hedge funds and private equity companies. Prior to the
enactment of Dodd-Frank, such advisers were able to avoid SEC
registration by reliance upon the 15-client, non-public adviser
exemption under the Investment Advisers Act of 1940. That exemption
from investment adviser registration was eliminated by the
Dodd-Frank legislation.
