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The Dodd-Frank Act, among other things, repealed §203(b)(3) of the Investment Advisers Act of 1940 (the “Advisers Act”) exempting an investment adviser with fewer than 15 clients in the preceding 12 months from registration. To address certain considerations arising from repeal of the fewer-than-15 client exemption, Dodd-Frank created new exemptions for:
As in the case of many Dodd-Frank provisions, implementation of the new exemptions is dependent upon regulatory action, in this case by the SEC. In the advisory, Jenner & Block Partner Paul F. Jock II summarizes the SEC’s recent actions in this regard.