Dodd-Frank Act May Require New SEC Registration for Non-U.S. Advisers
The Dodd-Frank Act may require many currently unregistered non-U.S. investment advisers to register with the SEC as investment advisers, because the Act eliminates a registration exemption on which many non-U.S. advisers have traditionally relied. Although we expect the deadline to be extended, if it is not extended, these registrations will be required to be completed by July 21, 2011.
This memorandum describes the new registration requirement, as well as certain new, more limited exemptions from registration under the Investment Advisers Act of 1940 available after Dodd-Frank, some of which may be useful to a non-U.S. investment adviser.
This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.
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