Compliance dates for the new Dodd-Frank adviser regulations will
likely be delayed until the first quarter of 2012, according to the
SEC. Dodd-Frank requires that the SEC complete rulemaking
concerning these provisions by July 21, 2011. In a letter posted on the SEC website,
Robert E. Plaze, associate director of the SEC's Division of
Investment Management, says that he anticipates the SEC will
complete its rulemaking on time, but will consider additional time
for compliance.
Private Fund Managers
Dodd-Frank makes a number of changes in the regulation of
investment advisers at the federal level. Many private fund
managers have relied on the exemption for advisers to fewer than 15
clients who do not hold themselves out to the public as being
investment advisers (Private Adviser Exemption). Dodd-Frank
eliminates the Private Adviser Exemption effective July 21, 2011,
and replaces it with several new exemptions including:
