Fall 2006

SEC Proposes New Rules For Hedge Funds and Their Managers

On December 27, 2006, the SEC proposed two new sets of rules aimed principally at hedge funds and their managers. First, the SEC proposed a broad anti-fraud rule applicable to investment advisers (whether registered with the SEC or not) of “pooled investment vehicles.” The second set of rule proposals would require natural persons investing in certain 3(c)(1) funds to have “investments” (as defined in the proposed rules) of at least $2.5 million at the time of investment (effectively replacing the current "accredited investor" standard for funds relying on 3(c)(1)).

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