Publications

President Obama signed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) into law on July 21, 2010, ending a two-year struggle to pass legislation framing the U.S. response to the global financial crisis that began in 2008. The Dodd-Frank Act will make the most sweeping changes since the 1930s in the way the U.S. financial system is supervised and regulated. The new law seeks to address the underlying causes of the crisis and to modernize the legal and regulatory framework that governs the ever more complex network of financial institutions known, to supporters and critics alike, as Wall Street.

Title IV of the Dodd-Frank Act, codified as the Private Fund Investment Advisers Registration Act of 2010, revises the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”), fundamentally altering the regulatory terrain for investment advisers to private funds. In this new environment, many non-U.S. investment advisers who previously were exempt from registration under the Advisers Act will be forced to register and to bear the costs of complying with an expanded set of applicable requirements. Certain non-U.S. investment advisers, however, may be eligible for exemptions from registration.

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