The recent global financial crisis prompted a far reaching legislative and regulatory response, the most notable of which was the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).1 Much has been written concerning the cause of the crisis and efforts to reduce future systemic risks to the financial system. By and large, the investment management business (investment advisers, mutual funds, exchange traded funds, hedge funds and private equity funds) did not play a significant role in bringing the crisis about, and as a result, the vast bulk of reform efforts have focused away from the investment management business.2

However, the wave of reform following the financial crisis did not entirely miss the investment management industry. In this article, we will focus on four significant reform efforts, some completed, some still a work in progress, that have directly targeted funds and their advisers. These four initiatives are: 1) money market fund reform, 2) registration requirements for hedge fund advisers, 3) higher net worth requirements for clients who are charged performance fees by their advisers and for investors in hedge funds, and 4) Commodity Futures Trading Commission (CFTC) regulation of investment advisers managing mutual funds that are deemed to be functioning as "commodity pools."3

Money Market Fund Reform