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ARTICLE · 24 NOVEMBER 2005

Investment Services Bulletin

Vedder, Price P.C.
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On October 26, 2004, the Securities and Exchange Commission (the "Commission") adopted a new rule and rule amendments (the "New Rules") that will require most hedge fund advisers to register as investment advisers under the Investment Advisers Act of 1940 ("Advisers Act").

United StatesFinance and Banking
Deborah Bielicke Eades
Deborah Bielicke Eades
Byron Hittle
Byron Hittle

Hedge Fund Update

On October 26, 2004, the Securities and Exchange Commission (the "Commission") adopted a new rule and rule amendments (the "New Rules") that will require most hedge fund advisers to register as investment advisers under the Investment Advisers Act of 1940 ("Advisers Act"). The New Rules may have a significant impact on hedge fund advisers, depending on the size, structure and operations of the adviser and its funds. Advisers who must register as a result of the New Rules must register under, and be in full compliance with, the Advisers Act no later than February 1, 2006.

Registration of Certain Hedge Fund Advisers

Impact of New Rules

The New Rules will require investment advisers to private funds that currently rely on the "private adviser" exemption1 to take the following steps on or before February 1, 2006:

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