kaal:claim:2337268-015

The pre Dodd-Frank exemption for advisers with fewer than fifteen clients failed as a regulatory boundary because most hedge fund advisers deliberately designed their operations and legal structures to fit within it and thereby escape SEC registration and supervision.

Most hedge fund advisers set up their operations and legal structure to comply with the former exemption so as to avoid registration and supervision by the SEC.28

Wulf A. Kaal, Investment Adviser Regulation (2013), 3. Registration, p. 9
https://ssrn.com/abstract=2337268 · source PDF

Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268

• hedge fund advisers before the enactment of Title IV in 2010

failuresupport: arguedfailure: exemption structuring around client count thresholdsfamily: regulatory-arbitragesecurities-lawregulatory-failureprivate-funds

• supports kaal:claim:2150377-008 Because Title IV's registration exemptions are broad enough to threaten the rule they qualify, the Dodd-Frank ...

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