Is the investment manager or general partner of a hedge fund required to register with the SEC in order to operate a hedge fund?
There is an exemption from registration at the SEC level where an investment adviser has less than 15 clients and the adviser does not hold itself out to the public as an investment adviser. Because the hedge fund itself is considered a single “client” of the adviser, this affords the adviser an exemption from registration. Investment advisers with less than $25 million are not permitted to register and may be subject to the state law and applicable rules.
