Effective July 21, 2011, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) eliminates the exemption from federal investment adviser registration which is currently available to advisers with fewer than 15 clients. In its place, Dodd-Frank includes several new exemptions, including one for certain foreign private advisers, one for advisers solely to venture capital funds, and one for advisers solely to private funds with assets under management in the United States of less than $150 million. The SEC has issued two releases proposing how these three new exemptions will work. The proposed regulatory structure will significantly change the provisions that apply to advisers and managers of private funds with their main place of business outside the United States.
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