In an interpretive letter dated January 18, 2012, the Office of Investment Adviser Regulation of the Division of Investment Management clarified the registration requirements of certain investment advisory affiliates. The “no-action” guidance effectively permits investment advisers to private funds to include certain affiliated advisers on the adviser’s Form ADV when they are considered a single advisory business.
The staff considered a situation when private fund advisers may advise their funds through a structure involving multiple entities, created for a variety of reasons (including tax, legal and regulatory). Though organized as separate legal entities, these advisers conduct a “single advisory business” because they...
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