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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

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