Title IV of the Act - entitled “Regulation of Advisers to Hedge Funds and Others”1 - eliminates the “private adviser” exemption from registration under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The “private adviser” exemption, formerly contained in Section 203(b)(3) of the Advisers Act, generally exempted from SEC registration any investment adviser that, in the course of the preceding twelve months, (i) had fewer than 15 clients and (ii) did not hold itself out to the public as an investment adviser or act as an investment adviser to any registered investment company or business development.
