By Dan Primack
November 22, 2010

The National Venture Capital Association has issued its first response to the SEC’s attempt to define “venture capital fund,” as required by the Dodd-Frank financial reform bill.

On blog, NVCA policy chief Jennifer Dowling writes:

The SEC staff provided a high level description of the proposal, which seeks to define venture capital investment based on several criteria including a lack of leverage and the non-public start-up nature of the companies in which we invest, rather than using a size-based criteria.  Finally there is a broad grandfathering provision so that only new funds must meet the definition.

These parameters are all very consistent with the messages NVCA has conveyed to SEC staff and Commissioners about the industry in recent weeks.  We are awaiting details of the proposal and will be better able to share a complete reaction once we have that information.

The SEC has launched a 45-day public comment period on the proposed language.

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