Proposed Rule: Rules Implementing Amendments to the Investment Advisers Act of 1940

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Date Received
Date Letter Type Commenter Name
Public Comment Gary A. LaBranche, FASAE, CAE, President & CEO, Association for Corporate Growth
Public Comment Sidney Wigfall, Managing Partner/Consultant, SC Advisors Group, Chicago, Illinois
Public Comment Pierre Bollon, AFG
Meeting with SEC Officials Memorandum from the Office of the Chairman regarding a May 26, 2011, meeting with representatives of the Equity Growth Capital Council
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding an April 12, 2011, meeting with representatives of the Managed Funds Association
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding an April 15, 2011, meeting with representatives of the Private Equity Growth Company Council
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding an April 12, 2011, meeting with representatives of the European Fund and Asset Management Association
Public Comment Howard Dicker, Chair, Securities Regulation Committee, Business Law Section, New York State Bar Association
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a March 14, 2011, meeting with various private fund investment advisers and service providers
Public Comment Shearman & Sterling LLP
Public Comment Lisa Tate, Vice President, Litigation & Associate General Counsel, American Council of Life Insurers
Public Comment Ki P. Hong and Patricia M. Zweibel, Skadden, Arps, Slate, Meagher & Flom LLP
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a March 1, 2011, meeting with representatives of Willowridge Partners, Venture Capital Fund of America, Private Equity Investors and Carter Ledyard & Milburn
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a February 22, 2011, meeting with representatives of Atlas Holdings LLC and Willkie Farr & Gallagher LLP
Meeting with SEC Officials Memorandum from the Office of Commissioner Casey regarding a March 1, 2011, meeting with representatives of Willowridge Partners, Venture Capital Fund of America, and PEI Funds
Meeting with SEC Officials Memorandum from the Office of Commissioner Casey regarding a February 22, 2011, meeting with representatives of Atlas Holdings and Willkie Farr
Public Comment Debevoise & Plimpton LLP
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a February 9, 2011, meeting with representatives of the ACA Compliance Group
Public Comment David Massey, Administrator, North Carolina Deputy Securities and President, North American Securities Administrators Association, Inc.
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a February 9, 2011, meeting with representatives of the Investment Adviser Association
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a meeting with representatives of the Investment Adviser Association, MFS Investment Management, and The Bank of New York Mellon
Public Comment Scott Reckamp, Capital Markets Compliance®, LLC
Public Comment Ken Taymor, Executive Director, and Eric Finseth, Lecturer and Research Fellow, Berkeley Center for Law, Business and the Economy, Berkeley, California
Public Comment Jeffrey W. Rubin, Chair, Committee on Federal Regulation of Securities, Section of Business Law, American Bar Association, New York, New York
Public Comment Jeffrey W. Rubin, Chair, Committee on Federal Regulation of Securities, Section of Business Law, American Bar Association, New York, NY
Public Comment Seward & Kissel LLP
Public Comment James Chanos, Chairman, Coalition of Private Investment Companies, New York, New York
Public Comment Addison Braendel, Baker & McKenzie LLP, Chicago, Illinois
Public Comment Christopher M. Salter, O'Melveny & Myers LLP, on behalf of the China Venture Capital and Private Equity Association, Hong Kong Venture Capital and Private Equity Association and the Singapore Venture Capital and Private Equity Association
Public Comment Georg Merkl, Binz, Switzerland

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-36-10
S7-36-10
Release Number
IA-3110
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