kaal:claim:2714974-003

The SEC's 1985 safe harbor in Rule 203(b)(3) allowed a limited partnership itself, rather than each of its limited partners, to be counted as a single client of the general partner acting as adviser, which is what kept hedge fund advisers below the registration threshold.

the safe harbor provision allowed a limited partnership, rather than each of its limited partners, to be counted as a "client" of a general partner acting as investment adviser to the partnership

Kaal and Oesterle, The History of Hedge Fund Regulation in the United States (2016), SEC Rules Requiring the Registration of Hedge Fund Managers, p. 8
https://ssrn.com/abstract=2714974 · source PDF

Kaal and Oesterle, The History of Hedge Fund Regulation in the United States (2016). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2714974

• applies to exemption from registration under the Investment Advisers Act of 1940

mechanismsupport: assertedprivate-fundssecurities-law

• extended_by kaal:claim:2998097-001 The Investment Advisers Act safe harbor let an adviser count an entire legal organization as one client, provi...

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