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Title IV: Regulation of Advisers to Hedge Funds and Others

American Bankers Association Contacts

Bob Davis  (202) 663-5588   (OTS and Thrifts)
Joe Pigg (202) 663-5480  (OTS and Thrifts)
Phoebe Papageorgiou (202) 663-5053

Dechert LLP Authors


Kevin Scanlan (212) 649-8716
Joseph J. Muscatiello (212) 698-3868


This title sets forth new parameters for federal and state registration of investment advisers and:

  • Introduces additional obligations relating to advisers to "private funds," which are defined as any issuer that would be an "investment company" (as defined in the Investment Company Act of 1940, as amended (the "1940 Act")) but for the exceptions to such status set forth in Sections 3(c)(1) and 3(c)(7) of the 1940 Act (i.e., most private equity funds, hedge funds, and venture capital funds); [§402(a)]
  • Adjusts certain net worth requirements that private fund investors need to satisfy; and
  • Commissions studies and reports relating to the private fund industry.


Title IV will become effective one year after the date of its enactment. [§419]


The following links provide expanded analysis within this section: