Amendments to the Private Fund Investment Advisers Registration Act

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.

References:

• Private Fund Investment Advisers Registration Act amendments hosted on JD Supra
• Archived Webcast (10/ 27/ 2009) of the House Committee hearing
• Full Committee Markup and text of amendments to the Private Fund Investment Advisers Registration Act