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SEC Rules on the Family OfficeSEC Rules on the Family Office

Family offices must now square the corners of their ownership and investment process with a new regulation. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) fundamentally changes the rules for family offices that provide investment advice. Prior to the passage of that law, many family offices considered themselves exempt from registration under the Investment Advisers Act

Miles C. Padgett, Partner

September 1, 2011

23 Min Read
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Miles C. Padgett

Family offices must now square the corners of their ownership and investment process with a new regulation. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) fundamentally changes the rules for family offices that provide investment advice. Prior to the passage of that law, many family offices considered themselves exempt from registration under the Investment Advisers Act of 1940 (Advisers Act) due to the exemption for advisers with fewer than 15 clients. In enacting Dodd-Frank, however, Congress revoked that exemption effective July 2011, but created a new exemption for family offices — the single family office exclusion — and directed the Securities and Exchange Commission to establish its scop...

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About the Author

Miles C. Padgett

Partner

http://www.kozlaw.com/

Miles has assisted clients in planning for their estates, varying in value from $10 million to over $4 billion and consisting of assets such as commercial real estate holdings, closely-held stock, non-qualified compensation, well-known art work, and high-value scenic real estate.  Miles has also assisted clients in establishing private trust companies (and other private fiduciary companies) for complex families and trust networks to create user-friendly and family goal-specific organizations.  


Miles writes and speaks on a wide variety of tax and wealth management topics.  

Miles was a founding member of the firm Kozusko Harris Vetter Wareh Duncan LLP, and resigned from the partnership in 2004 to join the financial services community.  After spending over 5 years as an investment consultant with Convergent Wealth Advisors, where he was a director in its Investment Strategy Group focusing on asset allocation and manager search and selection, Miles re-joined the firm as a partner in December 2009.

Miles earned a Bachelor of Arts degree, with distinction, from Cornell University and a Juris Doctor degree from Vanderbilt University, where he was a member of the Vanderbilt Journal of Transnational Law.  In addition to being a lawyer, Miles holds the Certified Investment Management Analyst (CIMA®) designation, from the Investment Management Consultants Association in conjunction with the Wharton School at the University of Pennsylvania.