The Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) enacted in July 2010 introduced significant changes to the regulation of investment advisers. The Securities and Exchange Commission has subsequently adopted several new rules implementing and further clarifying the changes contemplated by the Act. The SEC most recently adopted final rules that implement provisions of the Act eliminating the “private investment adviser” exemption to registration with the SEC under the Investment Advisers Act of 1940 (the “Investment Advisers Act”), establishing new exemptions from SEC registration for small private fund advisers and venture capital fund advisers (but introducing limited reporting requirements for those exempt advisers), transferring regulatory responsibility from the SEC to the states for mid-sized advisers, and revising the “pay-to-play” rule, among other changes. The SEC also adopted a final rule defining “family offices,” which are exempt from registration under the Investment Advisers Act.
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