Proposed Rule: Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers with Less Than $150 Million in Assets Under Management, and Foreign Private Advisers

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Date Received
Date Letter Type Commenter Name
Public Comment Sidney Wigfall, Managing Partner/Consultant, SC Advisors Group, Chicago, Illinois
Public Comment Craig T. Redinger, Fulbright & Jaworski L.L.P., Munich, Germany
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a June 1, 2011 Conference Call with Representatives of Davis Polk & Wardwell LLP
Public Comment Pierre Bollon, AFG
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a May 5, 2011 meeting with representatives of the European Fund and Asset Management Association and Dechert LLP
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding April 20 and May 9, 2011 conference calls with representatives of Autorité des Marchés Financiers de la République Française
Public Comment Deena Seelenfreund, Chief Financial Officer, VCFA Group; Bart Shirley, Managing Partner, Cuyahoga Capital Partners LLC; Chuck Stetson, Managing Director, PEI Funds ; Jason Andris, Managing Director, Venture Investment Associates; Jerrold Newman, President, Willowridge Partners, Inc.
Meeting with SEC Officials Memorandum from the Office of Commissioner Casey regarding a May 26, 2011, meeting with representatives of Private Equity Growth Capital Council
Public Comment Nora Jordan and Greg Rowland, Davis Polk & Wardwell LLP
Public Comment Jack Governale, Esq., Katten Muchin Rosenman LLP
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
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding an April 4, 2011, meeting with representatives of SVB Capital
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
Meeting with SEC Officials Memorandum from the Office of the Chairman regarding a March 16, 2011, meeting with representatives of Willowridge Partners, PEI Funds, VCFA Group, Cuyahoga Capital Partners, and Carter Ledyard & Milburn
Meeting with SEC Officials Memorandum from the Office of Commissioner Walter regarding a February 22, 2011, meeting with representatives of Atlas Holdings and Willkie Farr & Gallagher
Meeting with SEC Officials Memorandum from the Office of Commissioner Walter regarding a March 1, 2011, meeting with representatives of Willowridge Partners, PEI Funds, Venture Capital Fund of America, and Carter Ledyard & Milburn
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
Public Comment Marshall H. Cole II, Patrick A. Duncan, Benny LaRussa, Jr., James M. Micali, Porter B. Rose, R. Patrick Weston, Azalea Capital
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 Anne Simpson, Senior Portfolio Manager, Global Equity, California Public Employees' Retirement System (CalPERS)
Public Comment David Massey, Administrator, North Carolina Deputy Securities and President, North American Securities Administrators Association, Inc.
Public Comment Elizabeth Shea Fries, Goodwin Procter LLP
Public Comment Samuel L. Katz, Managing Partner, TZP Capital Partners I
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

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-37-10
Release Number
IA-3111
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