Simpson Thacher Attorneys Author Article on SEC’s Recent Changes to “Qualified Client” Definition
07.29.21
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Partners David Blass and Michael Wolitzer, Senior Counsel Allison Bernbach and Associates Manny Halberstam and Radhika Kshatriya authored an article titled, “SEC’s Recent Decision Regarding ‘Qualified Client’ Status,” which was published by the Harvard Law School Forum on Corporate Governance. The article analyzes the SEC’s recently issued Order raising the “net worth test” from $2.1 million to $2.2 million and raising the “assets under management test” from $1 million to $1.1 million for purposes of the “qualified client” definition in Rule 205-3 under the Investment Advisers Act of 1940. The article further notes that the new thresholds are effective beginning August 16, 2021, and that registered investment advisers charging performance-based compensation should timely revise their fund or client documentation accordingly.
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