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SEC Adopts Final Form PF: Certain Implications for Hedge Fund and Private Equity Fund Advisers

November 15, 2011

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On October 31, 2011, the SEC and the CFTC adopted final rules http://www.sec.gov/rules/final/2011/ia-3308.pdf under the Investment Advisers Act of 1940 and the Commodity Exchange Act, respectively, to implement Sections 404 and 406 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. New Advisers Act Rule 204(b)-1 requires investment advisers registered or required to register with the SEC that advise one or more "private funds" and have at least $150 million in "private fund assets" under management to file a Form PF with the SEC.

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