New York (HedgeCo.net) – Title IV of the Dodd-Frank Act is also known as the “Private Fund Investment Advisers Registration Act of 2010” (the “PF Act”). The PF Act amends the Investment Advisers Act of 1940 (the “Advisers Act”) and eliminates an exemption from investment adviser registration that is often claimed by hedge funds and other private fund managers. This common “Small Investment Adviser” exemption was for advisers with less than $25 million under management and fewer than 15 clients. Even though the PF Act provides some new exemptions that are detailed below many additional managers will be required to register as investment advisers with the Securities and Exchange Commission (the “SEC”) when the PF Act becomes effective.
The PF Act also imposes new record keeping and reporting requirements on private fund managers, transfers regulatory responsibility for certain mid-sized investment advisers from the SEC to the states and amends certain other sections of the Advisers Act.
