Registration, Exemption and Compliance Requirements for Private Fund Managers

Guest post by Jonathan A. Golub, Partner – Reitler Kailas & Rosenblatt LLC [1]

The Dodd-Frank Wall Street Reform and Consumer Protection Act, which became law in 2010, complicated the registration and compliance landscape for investment advisers, including those that manage private funds (referred to in this material as “private fund managers”). [2] The question for New York-based investment advisers managing private funds is whether they have to register with the Securities and Exchange Commission (the “SEC”), the State of New York, or multiple states. As discussed below, New York-based fund managers are treated differently under the law from fund managers domiciled in other states. This material focuses on how New York-based private fund managers should navigate the registration requirements of federal and state law.

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