In recent testimony before the Senate Banking Committee, SEC Chairman Mary Schapiro confirmed that the SEC would delay implementation of hedge and private equity fund adviser registration until the first quarter of 2012.  Ms. Schapiro's statements are consistent with those made by Robert Plaze, Associate Director of the SEC's Division of Investment, in a recent letter to NASAA indicating that the SEC would delay implementation of the hedge and private equity fund manager registration provisions as well as the transition period for advisers with $25-$100 Million in assets under management required to transition to state registration. 

OUR TAKE: As a technical legal matter, the SEC has yet to take action to actually postpone the registration deadline (currently July 21, 2011).  However, barring a major political upheaval, we think Congressional testimony by the SEC Chairman can serve as a basis for planning.