Overview

As of 31 March 2012, certain non-US investment advisers will be required for the first time to be registered with the US Securities and Exchange Commission under the Investment Advisers Act of 1940.

Previously, many non-US advisers relied on the "private adviser" exemption under the Advisers Act to avoid registration with the SEC. This exemption, which had provided an exemption from registration for investment advisers that had fewer than 15 US clients over the proceeding 12 months and did not hold themselves out to the public in the US as investment advisers, was removed from the Advisers Act by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

In this briefing, DLA Piper outline the three main exemptions from registration available to foreign private advisers and the implications of registration as an investment adviser.

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