Hedge Fund Regulation - Investment Adviser Reporting - Comment Letter - Managed Funds Association - January 24, 2011

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Dodd-Frank Timeline, Investment Adviser Reporting, Joint SEC-CFTC Rulemaking
Final Rule Issue Effective Date Compliance Date
November 16, 2011 March 31 2012 June 15, 2012*

Rules Implementing Amendments to the Investment Advisers Act of 1940
January 24, 2011

From the comment letter:

  • "The Commission should provide additional guidance to ensure that the activities of unregistered private fund managers that must register with the Commission are not unnecessarily disrupted;
  • Private fund managers that register in advance of the Effective Date should be able to file a single, comprehensive Form ADV;
  • The calculation of an investment adviser's regulatory assets under management should continue to: (i) provide flexibility with respect to including certain assets, (ii) represent an adviser's net assets, and (iii) be based on the valuation methodology described in a private fund's offering documents;
  • Sensitive information about a private fund and its manager should only be reported to the Commission on Form ADV; and
  • Private fund managers generally should not be subject to regulations that prohibit certain types of incentive-based compensation arrangements."


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