Investment Advisers Regulation - Exemptions - Comment Letter - National Venture Capital Association - January 13, 2011

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Dodd-Frank Timeline, Adviser Exemptions, SEC
Comment Deadline Final Rule Issue Effective Date
January 24, 2011 July 6, 2011 July 21, 2011

Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers with Less Than $150 Million in Assets Under Management, and Foreign Private Advisers
January 13, 2011

In the letter, the NCVA recommends:

  • that investment advisers be allowed no more than 15 percent of their committed capital be derived from non-qualifying activities under the venture capital fund exemption;
  • specific advice in regards to qualified portfolio companies, stock acquired via secondary transactions, and public company investments;
  • other technical comments; and
  • clarified definitions with regard to equity securities, non-U.S. investments, limits on public company holdings, managerial assistance and control, venture capital fund borrowing, venture capital fund redemptions.


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