On December 2, 2013, the SEC’s Division of Investment Management issued a new “Guidance Update” that provides some important interpretive guidance on the exemption from registration under the Investment Advisers act of 194 for certain venture capital fund advisers (the VC Exemption). In particular, the Guidance Update clarifies that certain structures and practices common in the venture capital fund industry will not impact the availability of the VC Exemption.
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