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SEC Provides Expanded Relief from Registration for Certain Affiliates of an SEC Registered Investment Adviser
February 1, 2012
On January 18, 2012, the Division of Investment Management of the SEC issued a no-action letter in response to a request for no-action relief from the American Bar Association's Subcommittee on Hedge Funds. The letter provides expanded relief from registration under the Investment Advisers Act to certain entities affiliated with an SEC-registered investment adviser, including authorizing a registered investment adviser to (i) maintain affiliates that serve as general partner or managing member of a private fund without registration of the affiliates as registered investment advisers, or (ii) maintain a "network" of controlled related entities that conduct a single advisory business without registration of these entities as registered investment advisers.