On July 21, 2010, President Obama signed into law the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act), which, among other things, significantly amended the regulatory requirements applicable to investment advisers under the Investment Advisers Act of 1940 (the Advisers Act). On June 22, 2011, the Securities and Exchange Commission (the SEC) adopted final rules under the Advisers Act implementing various aspects of the Dodd-Frank Act (the Final Rules). Below is a summary of some of the key provisions of the Final Rules and the impact that they will have on investment advisers, particularly advisers to private equity and hedge funds. Generally, the deadline for advisers who have previously been exempt from SEC registration and who must now register with the SEC under the Final Rules is March 30, 2012.
For more information regarding the new private fund investment adviser registration requirements our previous Legal Alert is available here.