# kaal:claim:2714974-003

**Claim.** 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.

**Type.** mechanism  **Support.** asserted

**Holds when.**

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

**Source quote.**

> 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

**From.** Kaal and Oesterle, *The History of Hedge Fund Regulation in the United States* (2016), SEC Rules Requiring the Registration of Hedge Fund Managers, page 8

**Cite as.** 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

**Verify.** sha256 of source PDF `7764601d3ed5bb056b58949e8411eff9dfb9855f143719062030c980c5fa801b` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20and%20Oesterle%20-%202016%20-%20The%20History%20of%20Hedge%20Fund%20Regulation%20in%20the%20United%20States.pdf

**Topics.** private-funds, securities-law

**Keywords.** investment-advisers-act, safe-harbor, client-counting, registration-exemption

**Related claims.**

- extended_by: https://wulfkaal.github.io/claims/2998097-001

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