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SEC Proposes Private Fund Systemic Risk Reporting Rule and Rule Amendments Relating to the Definition of Accredited Investor under Dodd-Frank

January 31, 2011

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On January 25, 2011, the U.S. Securities and Exchange Commission proposed new Rule 204(b)-1 under the Investment Advisers Act of 1940, as amended, which would require SEC-registered investment advisers that advise one or more "private funds" to file a new reporting form, Form PF, with the SEC. The information contained in Form PF is designed primarily to assist the Financial Stability Oversight Council in its assessment of systemic risk in the U.S. financial system. The amount and type of information reported, as well as the frequency of reporting, would vary based on both the size of the private fund adviser and the type of private funds it advises.

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