The staff of the SEC’s Division of Investment Management (the “Staff”) posted on the SEC website a set of responses to questions about Rule 202(a)(11)(G)-1 under the Investment Advisers Act of 1940 (the “Family Office Rule”), which provides an exclusion from the definition of “investment adviser” for a family office that meets the Rule’s conditions. (See the June 23, 2011 Goodwin Procter Alert for a detailed discussion of the Family Office Rule.) Topics covered are (1) ownership and control of the family office, (2) key employees, (3) family members, (4) non-advisory services and (5) the grandfathering provision. The Staff expects to update the posting from time to time.
Alert February 14, 2012