We have to register? At least now we can advertise!

In the wake of the Securities and Exchange Commission’s (the “SEC”) adoption of new rule 203(b)(3)‐2 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), many investment advisers that provide advisory services to hedge funds, and that previously had benefited from an exemption from federal registration under the Advisers Act, now will find that they are no longer eligible for such exemption. They will have to become federally registered investment advisers. As a result, such advisers will find themselves subject to a variety of rules and regulations regarding various compliance matters. Significantly, for the first time these advisers also may be able to market their services