On October 26, 2004, the Securities and Exchange Commission (SEC) voted to pass a new final rule which will require hedge fund managers who have 15 or more investors (i.e., investors in any hedge funds which the manager advises) to register with the SEC as an investment adviser under the Investment Advisers Act. However, if the hedge fund manager has less than $30 million in assets under management (e.g., a hedge fund in which investor commitments equal less than $30 million), such manager would generally be exempt from SEC registration (although the manager may be subject to state registration requirements). In addition, there are certain other requirements, exemptions and “grand-fathering” type provisions in the new rule. Compliance with the new rule will be required by February 2006. As soon as the final rule is published by the SEC, we will submit a full review of the new rule, its probable consequences and our advice on planning strategies.