kaal:claim:2150377-004

Before Dodd-Frank the perimeter of hedge fund regulation was set by SEC no-action letters on client counting and by courts that gave very limited and sometimes contradictory guidance, so compliance rested on an unstable and uncertain base rather than on rules.

However, the SEC continued to provide guidance mostly in the form of no-action letters to help investment advisers determine the counting of clients to stay exempt from securities regulation.44 Courts also provided very limited and sometimes contradictory guidance.45

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

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

• the period between the 1968 Merrill Lynch action and the 1985 safe harbor rule
• advisers seeking to stay exempt from securities regulation

failuresupport: arguedfailure: guidance-by-no-action-letterfamily: definitional-ambiguitylaw-and-legal-systemssecurities-lawprivate-funds

• specializes kaal:claim:1806252-018 A lack of regulatory guidance creates legal uncertainty, and legal uncertainty in turn generates transaction c...

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