New SEC no-action letter touches on AUM of foreign private fund adviser

IM won't recommend enforcement if the advisers "treats a Reserved Powers Trust as a Non-U.S. Person (each as described and defined in your letter) in determining the number of clients and private fund investors in the United States, or the amount of its assets under management attributable to clients and investors in the United States, for purposes of the thresholds set forth in such exemption"