# kaal:claim:2337268-016

**Claim.** The foreign private adviser exemption that replaced the fewer than fifteen clients exemption is conjunctive: it requires fewer than fifteen U.S. clients and investors, no U.S. place of business, no holding out to the U.S. public, and less than $25 million AUM attributable to U.S. clients and investors.

**Type.** condition  **Support.** asserted

**Holds when.**

- advisers claiming the foreign private adviser exemption after 2010

**Source quote.**

> have fewer than fifteen clients and investors in the United States, do not have a place of business in the United States, do not hold themselves out to the U.S. public as an investment adviser, and do not attribute more than $25 million AUM solely to U.S. clients and investors.30

**From.** Wulf A. Kaal, *Investment Adviser Regulation* (2013), 3. Registration, page 9

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

**Verify.** sha256 of source PDF `7075ce35282a8ee75b81ae3dec0e19f68631beae7f3c3a00ab2827538dc9e302` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20-%202013%20-%20Investment%20Adviser%20Regulation.pdf

**Topics.** securities-law

**Keywords.** foreign-private-adviser, registration-exemption, dodd-frank-title-iv, cross-border

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