tailieunhanh - SEC Finalizes Rules to Implement Dodd-Frank Act Regulation of Private Investment Funds and Their Managers

This positive sentiment extended to non-euro area banks, with UK banks experiencing positive inflows of € billion compared to inflows of €9 billion for euro area banks. The higher figure for the UK may be partially accounted for by rebalancing from sovereign to corporate bonds as UK government bonds experienced an outflow of € billion, to close at € billion, alongside upward revaluations of € billion. UK banks’ participation in ECB operations, through their subsidiaries and branches, is also likely to have contributed to investor confidence. . | PAUL HASTINGS STAY CURRENT A Client Alert from Paul Hastings July 2011 SEC Finalizes Rules to Implement Dodd-Frank Act Regulation of Private Investment Funds and Their Managers BY THE INVESTMENT MANAGEMENT PRACTICE On June 22 2011 the Securities and Exchange Commission the SEC adopted rules and rule amendments1 the Final Rules designed to implement a number of significant changes applicable to private investment funds and their managers imposed by the Dodd-Frank Wall Street Reform and Consumer Protection Act the Dodd-Frank Act .2 The SEC adopted a number of the rules substantially in the form originally proposed on November 19 Notable changes are as follows Compliance Deadline The Final Rules extend the deadline for private fund advisers not eligible for any exemption to register with the SEC to March 30 2012. Eligibility for SEC Registration The Final Rules clarify that advisers with assets under management in excess of 25 million and who have their principal office and place of business in New York Minnesota or Wyoming are required to register with the SEC unless an exemption is available . Venture Capital Fund Exemption The Final Rules made several changes to this exemption. Most notable is the revised definition of venture capital fund to include funds which invest up to 20 in non-qualifying investments rather than 100 in qualifying investments as proposed. Private Fund Adviser Exemption The Final Rules require an adviser seeking to rely on the private fund adviser exemption to calculate and report its assets under management on an annual basis rather than quarterly as proposed. Foreign Private Adviser Exemption The Final Rules do not require . advisers to count investors who are knowledgeable persons toward the 14 investor limit as originally proposed and expand on the definition of place of business for purposes of the requirement that the . adviser have no place of business in the United States. This Alert summarizes the aspects of the .