SEC Proposes New Disclosure and Reporting Requirements for Investment Advisers


On November 19, 2010, the Securities and Exchange Commission (the “SEC”) proposed new rules and amendments to existing rules and Form ADV under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), that would implement various amendments to the Advisers Act contained as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The proposed rules and amendments, summarized below, would, among other things, clarify the eligibility of advisers to register (or remain registered) with the SEC, modify the way advisers calculate their assets under management, establish reporting requirements applicable to “exempt reporting advisers” and require advisers to make additional disclosures on Form ADV.

To read the full alert, click on the PDF linked below. Topics include:

  • Eligibility for SEC Registration
  • Regulatory Assets Under Management
  • Reporting Requirements for Exempt Reporting Advisers
  • Amendments to Form ADV
  • Revisions to the Pay to Play Rule
  • Comment Period

For additional information regarding the proposed rules and amendments or any of the regulatory developments under the laws mentioned above, please contact one of the attorneys listed below:

Taylor H. Wilson

Evan K. Hall

Katherine Addleman

Richard M. Fijolek

Vicki L. Martin-Odette

Rick A. Werner


 David Siegal

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