Enacting legislation is often compared to making sausage. I don’t think that the Private Fund Investment Advisers Registration Act is exception. I spent some time watching the House Financial Services Committee hearing on passing the Private Fund Investment Advisers Registration Act.
There were 13 proposed amendments, 8 of which were agreed to by the Committee. I tried incorporating these amendments into the text to see what happened earlier this week.
You can see my attempt hosted on JD Supra
Here are some quick thoughts:
- The exemption for venture capital funds was retained.
- There is a new exemption for investment advisers of private funds with less than $150 million. (There was a rejected amendment trying to have this level at $500 million.)
- There is a one year transition rule, postponing the registration requirement until one year after the Act is passed.