TAILIEUCHUNG - South Carolina Securities Division Notice Regarding Investment Adviser Switch to State Registration

First, we show that the source of FI’s recent excellent performance is not from its ability to systematically arbitrage mispricing in a noisy market but from increasing the portfolio’s exposure to stocks with low price-to-book values and with small capitalizations. We find that FI does not produce a positive alpha when its excess returns are explained by the Fama-French three-factor model of CAPM beta, the value premium and the size premium. Second, we show that it is possible to construct a portfolio of exchange-traded funds with similar factor loadings that can replicate, and sometimes, even outperform FI. . | South Carolina Securities Division Notice Regarding Investment Adviser Switch to State Registration The Dodd-Frank Wall Street Reform and Consumer Protection Act Dodd-Frank Act increases states authority in the area of investment adviser regulation by raising the threshold from 25 million to 100 million assets under management AUM . Generally speaking this affects those investment advisers registered with the Securities and Exchange Commission SEC with less than 100 million in AUM and they must switch to state registration from SEC oversight. On June 22 2011 the SEC issued final rules implementing the Dodd-Frank Act s required changes including postponing the switch deadline from July 21 2011 to March 30 2012. A complete copy of the rules was published in the Federal Register at http fdsys pkg FR-2011 -07-19 pdf 2011 . This extended deadline provides additional time for investment advisers to determine whether they are still eligible for SEC registration. Investment advisers registered with the SEC as of July 21 2011 should remain registered with the SEC until January 1 2012 unless an exemption from SEC registration is available . Investment advisers no longer eligible for SEC registration have until June 28 2012 to register with the appropriate state regulator s and to withdraw their SEC registration. The South Carolina Securities Division encourages all federally covered investment advisers with less than 100 million under management who are currently Notice Filed in South Carolina to initiate registration in South Carolina as soon as possible. This will allow the investment adviser to continue providing investment advisory services under the authority of the SEC while South Carolina reviews the investment adviser s application for registration. Below is a list of frequently asked questions. These are updated as new information is received so please check this site periodically. Frequently Asked Questions Q What does it mean to be a state .

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