kaal:claim:2150377-003

The client counting safe harbor, which let an adviser count a pooled entity rather than each investor as a single client, allowed advisers to manage large amounts of securities indirectly for several hundreds of investors across multiple hedge funds while remaining outside registration and supervision.

Source quote, verbatim

This safe harbor allowed investment advisers to manage large amounts of securities indirectly for several hundreds of investors in several hedge funds.53

From

Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012), A. Attempts To Register Hedge Funds
https://ssrn.com/abstract=2150377 · source PDF

Cite as

Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377

Holds when

under the 1985 safe harbor as broadened in 1997
before the Dodd-Frank Act repealed the private adviser exemption

Classification

mechanismsupport: arguedfailure: client-counting-safe-harbor-loopholefamily: regulatory-arbitrageinstitutional-design

Verify

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Attestation record: colloquium/attestations/80568274bafb7a9b...json
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