Private Fund Adviser Registration Deadline May Be Extended To First Quarter 2012

April 11, 2011

The SEC’s Division of Investment Management has indicated in an April 8th letter to the North American Securities Administrators Association that the SEC staff expects “that the Commission will consider extending the date by which [private fund] advisers must register and come into compliance with the obligations of a registered adviser until the first quarter of 2012.” In the same letter, it also states that “the Commission will consider extending the date by which mid-sized advisers must transition to state regulation.” We are monitoring this matter very closely, and will apprise you promptly of any new developments. If you have any questions, please contact your primary attorney in the Investment Management Group.