Subject: File No. DF Title IV - Exemptions
From: P James

August 21, 2010

The commentator from California on venture capital funds makes little sense as as the California definition of venture capital fund will include substantially all private equity funds of any type not just venture funds. Management services are provided or at least offered in almost all private equity fund investments to avoid ERISA regulation and the California exemption is currently used by both types of funds. Your definition of venture capital should focus on size of investment and early stage of company development.