Wednesday, January 25, 2012

Private Fund Managers and SEC Registration

"The SEC has provided a no action letter in response to an American Bar Association request on guidance for private fund managers. The ABA requested clarification that a group of funds could use a singe registration where the fund managers are in a control relationship and conduct a single advisory business subject to a unified compliance program. The theory is that permitting a single registration (and a single Form ADV filing) to cover the entire group of related advisers would more accurately reflect the full nature and scope of the single advisory business conducted by the group. Therefore it would be more informative for advisory clients and private fund investors as well as the SEC."

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