On July 14, 2004, in a 3-2 vote, the Commissioners of the Securities and Exchange Commission (SEC) proposed Rule 203(b)(3)-2 to be promulgated under the Investment Advisers Act of 1940, as amended (the Act), which would require certain hedge fund managers with more than $25 million under management to register as investment advisers under the Act. Concurrently, amendments to the Rules concerning custody, performance fees, performance disclosure and deadlines for financial statements relating to hedge fund managers were also proposed.
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