Client Alert - Investment Management - SEC Adopts Inflation Adjusted Definition of “Qualified Client” Under The Investment Advisers Act

On July 12, 2011, the Securities and Exchange Commission (the "SEC"), issued Release No. IA-3236 (7/12/11) (the "Order"), raising the dollar amount thresholds in Rule 205-3 under the Investment Advisers Act of 1940 (the "Advisers Act") for purposes of the rule’s exemption under the Advisers Act permitting the payment of performance fees to registered investment advisers by "qualified clients."