In a letter to the North American Securities Administrators Association, Inc. dated April 8, 2011, Robert Plaze, the Associate Director of the SEC’s Division of Investment Management, stated that the SEC anticipates completing its rulemaking to implement two provisions of the Dodd-Frank Act by July 21, 2011 (as instructed by Congress), but expects that the SEC will consider extending the date by which affected advisers must come into compliance with the newly adopted rules until the first quarter of 2012. The two provisions Mr. Plaze referred to are:
- the date by which advisers relying on the “private adviser exemption” that is being repealed by Dodd-Frank (private fund advisers) must register and comply with the obligations of a registered investment adviser; and
- the date by which mid-sized advisers (certain advisers having between $25 million and $100 million assets under management) must transition from SEC to state registration.
A copy of the letter is available at: http://www.sec.gov/rules/proposed/2010/ia-3110-letter-to-nasaa.pdf.