Proposed Legislation Creates Uncertainty Around SEC Family Office Exemption

If passed, proposed legislation H.R. 4620 would change the definition used by the SEC for the Family Office Exemption resulting in some Family Offices no longer qualifying for the exemption. Also, under the legislation the SEC would require Family Offices to maintain such records and provide such annual or other reports deemed necessary to the SEC. While advisors continue to watch the legislative path of H.R. 4620, a private trust company—as a state chartered bank—is exempt from the definition of Investment Adviser.