Investment advisors, including hedge fund managers, are subject to new registration and reporting requirements as a result of changes implemented by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank“). In general, if an investment advisor has less than $25 million in assets under management, the adviser is not eligible for SEC registration and must look to the laws of the advisor’s home state to determine registration and licensing requirements. Advisors registered in their home state can avoid SEC registration until they reach $100 million in assets under management. Advisors that only manage hedge funds and other private funds can avoid registration until they reach $150 million in assets under management. Dodd-Frank also increases reporting requirements for hedge fund managers with more advisors reporting on Form ADV and new Form PF.
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