Title

Dodd-Frank Act May Require New SEC Registration for Non-U.S. Advisers
Client Memorandum

Created date

4/25/2011

The Dodd-Frank Act may require many currently unregistered non-U.S. investment advisers to register with the SEC as investment advisers, because the Act eliminates a registration exemption on which many non-U.S. advisers have traditionally relied.  Although we expect the deadline to be extended, if it is not extended, these registrations will be required to be completed by July 21, 2011.

This memorandum describes the new registration requirement, as well as certain new, more limited exemptions from registration under the Investment Advisers Act of 1940 available after Dodd-Frank, some of which may be useful to a non-U.S. investment adviser.