kaal:claim:2998097-001

The Investment Advisers Act safe harbor let an adviser count an entire legal organization as one client, provided the advice followed the organization's objectives rather than those of its individual owners, which is what allowed advisers to manage money for hundreds of underlying investors while staying exempt.

investment advisers to private investment funds were able to count a legal organization as a single client provided the investment advice was based on the objectives of the legal organization rather than the individual investment objectives of any owners of the legal organization.

Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017), II.2 Evolution of the Investment Advisers Act Exemption, p. 8
https://ssrn.com/abstract=2998097 · source PDF

Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017). SSRN: https://ssrn.com/abstract=2998097

• United States
• before the Dodd-Frank Act of 2010

mechanismsupport: arguedprivate-fundssecurities-law

• extends 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 lim...
• extends kaal:claim:2714974-004 Expanding the client counting safe harbor in 1997 to cover legal entities generally allowed investment adviser...

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