One of the most fundamental Dodd-Frank changes affecting private funds is the elimination of the “private advisers” exemption from registration with the SEC as an investment adviser (also known as the “15-client” exemp- tion). In its place, Dodd-Frank created several new, but less comprehensive, exemptions, with the result that most . fund managers with $150 million or more in assets under management will need to register with the SEC, and most fund managers that also have non-fund clients (such as separately managed accounts) will need to reg- ister with the SEC or a state. Those changes are discussed in a separate article.
