SEC's Exemption Begging Rule: From $15K to Quarter-Mil Drama
Published Date: 3/19/2025
Notice
Summary
The SEC wants to keep Rule 0-4, which helps investment advisers and related folks ask for special permission to skip certain rules. About 7 applications come in yearly, costing applicants between $15,000 and $240,000 depending on how tricky their requests are. The SEC is asking for public comments before extending this rule, so everyone affected has a chance to weigh in.
Analyzed Economic Effects
2 provisions identified: 0 benefits, 2 costs, 0 mixed.
Applicants Face Large Counsel Fees
Registered investment advisers, affiliated persons, and entities seeking to avoid investment-adviser status may file up to 7 applications a year under Rule 0-4. Preparing those applications typically uses outside counsel and costs between $15,259.94 and $238,761.88 per application; the SEC estimates an annual total cost burden of $440,387.38 (1 complex at $238,761.88; 3 medium at $51,948.56 each; 3 routine at $15,259.94 each).
Applicants’ Responses Are Not Confidential
If you submit a Rule 0-4 application, your responses will not be kept confidential under this collection of information. The collection is used to decide whether exemptive relief is appropriate and responses will be publicly accessible as part of the SEC process.
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Key Dates
Department and Agencies
Related Federal Register Documents
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