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Real Estate Fund Advisers And Penumbra Registration

Last August, the Securities and Exchange Commission adopted amendments to Form ADV, the form used by investment advisers to register with the SEC and with the states.  Included in these amendments were changes to allow multiple private fund adviser entities operating a single advisory business to file one Form ADV.  These changes formalized prior staff guidance…

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More On Real Estate Funds And The Investment Advisers Act

In a previous post, I began to delve into the question of what is a “real estate fund”.  See SEC Staff Reports On “Real Estate Funds”, But What Exactly Are They?  As noted in that post, a “real estate fund” as defined in Form PF cannot be a company excluded from the definition of an “investment…

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SEC Staff Reports On “Real Estate Funds”, But What Exactly Are They?

Yesterday, the SEC staff announced that it had published a suite of new data and analyses of private fund statistics and trends.  These data include information with respect to “real estate funds”.  But what exactly is a “real estate fund”?  The answer is more than just a little arcane. The SEC gathers the data from Form PFs.  You are required…

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Rule 260.204.9 – What is to be Done (Part II)?

Last August, I wrote about the impact of the Dodd-Frank Act on Rule 260.204.9 in this post.  Last Thursday, I attended a meeting called by the Department of Corporations to solicit input from persons with an interest in the rule.  Technically, the meeting was held in accordance with Government Code § 11346.45.  That statute requires…

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