Alert May 17, 2011

SEC Chairman Testifies that Private Adviser Registration under Dodd Frank Expected to Occur in Q1 2012

Consistent with recent SEC correspondence to NASAA and members of Congress, SEC Chairman Mary L. Schapiro stated in her testimony before the Senate Committee on Banking, Housing and Urban Affairs that the registration of hedge fund advisers and private equity advisers with the SEC pursuant to Title IV of the Dodd-Frank Act is expected to occur in the first quarter of 2012.  The SEC has not yet taken formal action to delay the compliance date for the Dodd-Frank Act’s changes to the federal adviser registration scheme, which under the strict terms of Title IV are effective July 21, 2011.  In addition, the SEC has not yet taken final action on Dodd-Frank related rule proposals, such as those defining new venture capital adviser and private fund adviser exemptions.