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SEC Staff Grants No-Action Relief from IA Registration for Certain Advisers of Venture Capital Funds

The SEC Division of Investment Management granted no-action relief regarding Section 203(l) ("Registration of Investment Advisers") of the Advisers Act and the definition of "venture capital fund" thereunder for certain investment managers.

In particular, the letter relates to whether a fund can be considered a "venture capital fund" if certain companies it invests in do not technically meet the definition of "qualifying portfolio company" under IAA Rule 203(l)-1 ("Venture Capital Fund Defined").

Primary Sources

  1. SEC No-Action Letter
  2. Request for No-Action Relief; Cadwalader Memorandum ("SEC Adopts Dodd-Frank Act Investment Adviser Rules and Delays Implementati

Tags

Regulated Activities
Registration Requirement
Regulated Entities
Adviser / CTA / CPO Investment Funds (SEC Exempt)
Sub-Entity
Venture Capital Funds
Regulated Products
Investment Funds (as Regulated Product)
Sub-Product
Private Funds
Body of Law
Securities Law
Jurisdiction
US - Federal
Organization
SEC