Client Alert
The staff of the Securities and Exchange Commission recently provided guidance on various issues regarding investment adviser registration under the Investment Advisers Act of 1940. The SEC staff issued the guidance in response to a request by the American Bar Association, Business Law Section. The SEC staff previously commented on many of the same issues in a letter addressed to the American Bar Associationʼs Subcommittee on Private Investment Entities in 2005 in connection with the SECʼs 2004 rules that sought to require hedge fund managers to register under the Advisers Act. The current guidance clarifies certain matters in light of recent changes under the Dodd-Frank Wall Street Reform and Consumer Protection Act.