December 16, 2010
NASAA Proposes Model Rule on Registration and Reporting Requirements for Advisers to Private Funds
Dodd-Frank made significant changes to the provisions governing the regulation of investment advisers under the Investment Advisers Act of 1940 (“IAA”). In addition to expanding the states’ oversight of investment advisers by increasing the assets under management threshold for registration with the Securities and Exchange Commission (“SEC”), the Act made substantial changes to the regulation of investment advisers to hedge funds and other private funds. The implementation of these provisions and others is the subject of two releases recently issued by the SEC for comment. In Release No. IA-3110 and Release No. IA-3111 the SEC explains how the agency intends to implement the new registration and reporting requirements for investment advisers as well as other changes required under the Dodd-Frank Act.
NASAA is considering adopting a model rule governing the registration and reporting requirements for advisers to private funds. NASAA’s proposal is designed to follow certain provisions in the Dodd-Frank Act as implemented by the SEC, and, therefore, is contingent in many respects on how the SEC moves forward on implementation in this area. Consequently, if the SEC makes significant alterations to its proposals NASAA may be required to reevaluate the provisions in any proposed model rule or rules
NASAA is seeking comments on the proposed rule in general and is particularly interested in comments as to the scope of the rule. The deadline for submission of comments is January 24, 2011.
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