SEC Adopts Rules Implementing New Regulatory Regime For Investment Advisers

The U.S. Securities and Exchange Commission recently adopted a series of new rules and amendments to existing rules¹ under the Investment Advisers Act of 1940 so as to implement provisions of Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act² relating to the registration of investment advisers, including private fund managers. These rules (i) extend the deadline for adviser registration with the SEC, (ii) include clarifications of certain exemptions from investment adviser registration that the Dodd-Frank Act created last year, (iii) implement new thresholds for adviser registration with the SEC, and (iv) create a reporting regime for certain advisers that are exempt from adviser registration under the new rules. This client alert provides a brief overview of some of the key provisions of the new SEC rules.