SEC Approved Rules To Implement Provisions Of The Dodd-Frank Act, Delaying Implementation Until 2012

On June 22, 2011, the Securities and Exchange Commission (SEC) held an open meeting to consider approving three final rule proposals relating to the implementation of various portions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). Specifically, the Commission approved the Dodd-Frank Implementation Release (the Implementation Release), the Dodd-Frank Exemptions Release (the Exemptions Release) and the Family Office Release. The first was approved by a 3-to-2 vote and the other two were approved unanimously.

As expected, the SEC approved deferring the effective date for an investment adviser that is required to register with the SEC under Dodd-Frank to March 30, 2012. Newly registered investment advisers will therefore need to submit registration materials no later than mid-February 2012.