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New ERISA Reporting and Disclosure Rules and Guidance Appear to Favor VCOC/REOC Compliance Over 25% Test Reliance (PDF)
Paul, Hastings, Janofsky & Walker LLP 
[Guidance Overview] Aug. 7, 2008
3 pages. Excerpt: One surprising aspect of these new rules is that they appear to apply to investment funds that rely on the '25% Test' for their exemption from ERISA, while investment funds that qualify as 'venture capital operating companies' ('VCOCs') or 'real estate operating companies' ('REOCs') are specifically exempt from these rules.
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