Hedge Fund Transparency Act
By The Investment Management Practice
On January 29, 2009, Senator Charles Grassley, Republican of Iowa, and Senator Carl Levin, Democrat of Michigan, proposed new legislation (the Bill) regarding the regulation of hedge funds in the Hedge Fund Transparency Act. If passed, the Bill would change current law so that certain larger private investment funds, including hedge funds, private equity funds, venture capital funds and real estate funds (collectively, private funds) would now be required to register with the Securities and Exchange Commission (the SEC) and meet certain basic disclosure obligations. Private funds with aggregate assets in excess of $50 million must meet additional requirements and their managers may also be required to register with the SEC as investment advisers. The Bill would also require all private funds to establish anti-money laundering programs and report suspicious transactions.