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The SEC has provided a no action letter in response to an
American Bar Association request on guidance for private fund managers. The ABA
requested clarification that a group of funds could use a singe registration
where the fund managers are in a control relationship and conduct a single
advisory business subject to a unified compliance program. The theory is that
permitting a single registration (and a single Form ADV filing) to cover the
entire group of related advisers would more accurately reflect the full nature
and scope of the single advisory business conducted by the group. Therefore it
would be more informative for advisory clients and private fund investors as
well as the SEC.
The SEC agreed, subject to the following limits:
If I'm reading this right, it looks like you may be able
to wrap the registration requirement for the general partners of funds into a
single Form ADV Registration. Prior to this no action letter, I assumed you
needed to have each general partner enter into an investment management
agreement with the management company.
Given this, it looks like you may be able to take that
item off your list of things to do in the next few weeks and merely list the
general partners on the Form ADV (assuming you meet the other requirements).
additional commentary on developments in compliance and ethics, visit Compliance Building,
a blog hosted by Doug Cornelius.
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Hi, This is such a nice blog and It is really helpful for me, But i am looking for the Private Registration related post, So please suggest and share if you have. Thanks