We want to take this opportunity to urge all investment advisers for private equity and hedge funds, as well as venture funds, leveraged buyout funds and the like, that the time the SEC permitted for these entires to transition to registered investment adviser status will expire on March 30, 2012. That is, registration will be required at that time.
Notably, there is a revised Form ADV that investment advisers will be required to complete with many descriptions being in “plain English.” Further, it is essential that there be a quality compliance program in place headed by a chief compliance officer. The SEC has made it very clear that it will require proper supervision for all of these newly registered investment advisers.
As a result, we strongly urge these investment advisers to contact us to discuss the impact of these registration requirements as well as for assistance that we may be able to offer to them.