With the financial reform bill set to eliminate the 15 client rule exemption for registration under the Investment Advisers Act, the only remaining exemption for fund companies with over $150 million in assets under management will be for venture capital. The Congressional conference decided to not include the Senate’s exemption for private equity. The bill [...]
Tag Archives: Restoring American Financial Stability Act
Regulation of Advisers to Private Funds
One of the differences between the Senate and House financial reform bills is how they treat advisers to private equity funds. The Senate bill has an exemption for private equity and venture capital. The House bill only has an exemption for venture capital. Since I work for a private equity firm, I am very focused [...]
Private Equity and the Custody Rule
With the impending removal of the 15 Client Rule exemption from registration with the SEC, I was scratching my head trying to figure how to make the SEC’s new custody rule work for private equity. The SEC recently updated its guidance on custody rule compliance truing to add clarity for advisers to pooled investment vehicles. [...]
Private Fund Manager Registration Status
Shearman & Sterling put together a great client publication on private fund manager registration requirements being considered by Congress: Private Fund Manager Registration as U.S. Financial Reform Legislation Approaches the Finish Line. Among the many provisions to be reconciled in the 1,600+ pages of each bill are those that would require private fund managers to [...]
Side-by-Side Comparison Chart of Financial Reform Bills
The Wall Street Reform and Consumer Protection Act of 2009, passed by the House on December 11, 2009 is over 1300 pages long. The Restoring American Financial Stability Act of 2010, passed by the Senate on May 20, 2010, is over 1600 pages long. You have lots of reading to figure out the differences between [...]
Full Text of the Dodd Bill
The Restoring American Financial Stability Act of 2010 has been published in the form passed by the Senate last night. Full Text of S.3217 in PDF (its a big file, 1566 pages)
Dodd Bill, Private Placements and Accredited Investors
I previously wrote about how the Restoring American Financial Stability Act being tossed around in the Senate could affect private investment funds by changing the definition of accredited investor and altering the process for a Regulation D private placement. It looks like much of that is going to be wiped out of the bill. Senate [...]
Accredited Investors under the Restoring American Financial Stability Act
One of the surprises in the Restoring American Financial Stability Act of 2010 is that it proposes to raise the standard for being an accredited investor. Section 412 of the bill would require the SEC to increase the dollar thresholds to be qualified as an accredited investor. Section 413 would require the GAO to study [...]
Financial Overhaul Moves Forward
With the health care reform now out of the hands of Congress, there is now movement with financial overhaul. Senator Dodd introduced the Restoring American Financial Stability Act of 2010 last week without a Republican co-sponsor [Dodd Goes Solo]. Instead plugging in amendments, the Senate Banking Committee voted on straight party lines to advance the [...]
Dodd’s Solo View on Private Investment Funds
Senator Dodd did not forget about private investment funds. Tucked into page 366 of his 1366 page Restoring American Financial Stability Act of 2010 is the Private Fund Investment Advisers Registration Act. This is largely the same language in the Private Fund Investment Advisers Registration Act of 2009 contained in Dodd’s draft Restoring American Financial [...]
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