There is a lot happening in the Dodd-Frank Wall Street Reform and Consumer Protection Act. (Yes, that appears to be the agreed upon name of the financial reform bill.) I’m most interested in its Title IV: Private Fund Investment Advisers Registration Act of 2010(.pdf). The act will remove the current exemption from SEC registration for … Read more »
Tag: Wall Street Reform and Consumer Protection Act
It Will be up to the SEC to Define Venture Capital
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 … Read more »
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 … Read more »
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. … Read more »
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 … Read more »
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 … Read more »
Dodd Goes Solo
After months of negotiation, Senator Dodd gave up on his negotiations with Republicans and decided to introduce a financial industry reform bill all by himself. To promote the financial stability of the United States by improving accountability and transparency in the financial system, to end ‘‘too big to fail’’, to protect the American taxpayer by … Read more »
House Passes Far-Reaching Bill Tightening Financial Rules
Today, the House passed the Wall Street Reform and Consumer Protection Act of 2009 (H.R. 4173 ), a week after it was introduced. It looks it is a mashup of other bills that were being tossed around in the House to regulate the financial industry. According to Carl Husle of the New York Times, “After … Read more »