Sep 28, 2012
The Hedge Fund Law Report published an article titled "JOBS Act: Proposed SEC Rules Would Dramatically Change Marketing Landscape for Hedge Funds" by Shearman & Sterling partner Nathan J. Greene (New York, Investment Funds) on September 6, 2012.
When the JOBS Act (formally the Jumpstart Our Business Startups Act) was signed by President Obama in April, it directed that one of its most transformational provisions – the relaxation of decades-long limits on public offerings of unregistered securities – not go into effect until the Securities and Exchange Commission (SEC) set rules to implement the changes. This article describes the political debate surrounding the JOBS Act and analyzes the proposed SEC rules and their implications for investment fund managers with respect to the Investment Advisers Act, the Investment Company Act, the Commodity Futures Trading Commission rules and Regulation S.
For further information, see Shearman & Sterling's client publication on the proposed SEC rules here.