Strictly Business
A legal blog on private funds, startups, and venture capital.
Strictly Business
A legal blog on private funds, startups, and venture capital.
Tag Investment Adviser
Maryland Securities Commissioner Issues New Order Adopting a Private Fund Exemption Based on Model NASAA Rule
On June 15, 2012, the Maryland Securities Commissioner issued an order adopting the NASAA model rule exemption for investment advisers to private funds. Like the model rule, the new order issued by the Maryland Securities Commissioner, provides for an exemption…
Missouri Commissioner of Securities Proposes New Private Fund Exemption Based on Model NASAA Rule
On April 26, 2012, the Missouri Commissioner of Securities proposed revised regulations exempting certain private fund managers from investment adviser registration with the State of Missouri. Background Prior to the repeal of the federal 15-client exemption, Missouri had an exemption for…
Massachusetts Securities Division Adopts Final Private Fund Adviser Exemption Based Upon NASAA Model Rule
Previously, I reported that the Massachusetts Securities Division had proposed an exemption from investment adviser registration for advisers to private funds. In late winter, the division adopted these regulations as final (with small changes). They are, more or less, identical…
The SEC Increases the Net Worth Requirement of the Definition of “Qualified Client” Impacting Both Registered and Some Unregistered Private Fund Managers
Private fund managers who are registered with the SEC are required to follow federal regulations on performance compensation. Generally, if a registered fund manager desires to collect fees based on fund performance (such at the typical 20% carried interest), then…
Virginia Division of Securities Proposes New Private Fund Exemption Based on Model NASAA Rule
On February 14, 2012, the Virginia Division of Securities and Retail Franchising proposed revised regulations exempting certain private fund managers from investment adviser registration with the Commonwealth of Virginia. Background Prior to the repeal of the federal 15 client exemption,…