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ARTICLE · 21 JULY 2011
Financial Services Alert - July 19, 2011
Goodwin Procter LLP
The SEC issued an order that increases two dollar amount thresholds in Rule 205-3 under the Investment Advisers Act of 1940 related to "qualified client" status; the Rule permits a registered adviser to charge a qualified client, i.e., one that meets one or the other of these thresholds (or satisfies alternative criteria under the Rule) a fee based on a share of capital gains on, or capital appreciation of, the client’s account (a "performance fee"). Currently, under the two tests in question, a
United StatesFinance and Banking
