AIMA and ACC file response to SEC private fund advisers rulemaking

Published: 27 April 2022

On 25 April, AIMA and the ACC filed their response to the SEC's proposed new rules and amendments under the Advisers Act of 1940, governing the activities of private fund advisers (the "Proposal").  If adopted in its current form, the Proposal would fundamentally transform the private fund industry, including in ways that will have significant unintended and adverse consequences for investors.

Specifically, AIMA and the ACC wrote that the Proposal would:

  • harm investors through diminished efficiency and competition in the private fund market;
  • disproportionately harm small advisers;
  • increase the costs borne by investors; and 
  • unnecessarily divert the Commission's resources from protection of retail investors towards the protection of sophisticated, knowledge investors who can retain and/or have access to professional advisors in connection with their investments in private funds.

Click here for AIMA and the ACC's response.  Please reach out to Jennifer Wood with any questions.