Dodd-Frank Act: To extend, or not to extend: That is the question
Discussions around the Dodd-Frank Act continue to dominate the media as investment advisers await clarity on what is expected of them and concrete deadlines.
On May 12, 2011, SEC Chairman Mary Schapiro stated in a testimony before the U.S. Senate Committee on Banking, Housing and Urban Affairs that "Under Title IV of the Dodd-Frank Act, hedge fund advisers and private equity fund advisers will be required to register with the Commission, which is expected to occur in the first quarter of 2012." While the extension has yet to be made official, it is expected.
Without the extension, the current 2011 Dodd-Frank Act deadlines for investment adviser filings are:
May 30, 2011 for Part 2A delivery to existing clients;
July 31, 2011 for delivery of Part 2B to new/prospective clients;
August 20, 2011 to file an amendment to ADV regarding AUM;
September 30, 2011 for delivery of Part 2B to existing clients; and
October 19, 2011 to file ADV-W if an investment adviser is no longer eligible to remain registered with the SEC.