# kaal:claim:2998097-001

**Claim.** 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.

**Type.** mechanism  **Support.** argued

**Holds when.**

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

**Source quote.**

> 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.

**From.** 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, page 8

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

**Verify.** sha256 of source PDF `0955054f49c7011d33c285579bb046e6b284e42755b10fd2546a728c202669d5` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20-%202017%20-%20Private%20Investment%20Fund%20Regulation%20-%20Theory%20and%20Empirical%20Evidence%20from%201998%20to%202016.pdf

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

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

**Related claims.**

- extends: https://wulfkaal.github.io/claims/2714974-003
- extends: https://wulfkaal.github.io/claims/2714974-004

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