On July 21, 2010, President Obama signed into law The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”), which significantly changes the landscape for investment advisers operating in the United States or taking investment from United States persons. Among other things, Dodd-Frank eliminates the “private adviser” exemption from the registration requirements of the Investment Advisers Act of 1940. Although most provisions of Dodd-Frank have a four-year phase-in period, provisions affecting private funds become fully effective in one year. As a result, investment advisers within and outside the U.S. must evaluate how Dodd-Frank will affect their business and determine whether they must register in the U.S.

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