SEC Adopts Final Rules Regarding Investment Adviser Registration

On June 22, 2011, the Securities and Exchange Commission (the "SEC") adopted final rules¹ which implement certain provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). Among other things, the final rules adopted by the SEC: (i) provide an extension to the SEC registration deadline for advisers currently relying on the "private adviser exemption," including hedge fund and private equity fund advisers, until March 30, 2012, (ii) implement exemptions from SEC registration for certain venture capital fund advisers, private fund advisers and foreign private advisers, (iii) reallocate regulatory oversight of investment advisers among the SEC and the individual states, (iv) expand disclosure obligations, (v) define the term "family offices" that are to be excluded from SEC regulation and (vi) revise the "pay-to-play" rule. Set forth below is a high-level summary of the final rules.