EFTA00673837.pdf

From: "Lawrence H. Summers" < To: Jeffrey Epstein <jeevacation@gmail.com> CC: lhsoffice Subject: Fwd: Summers / DE Shaw Date: Wed, 29 Jul 2015 19:50:45 +0000 FYI Sent from my iPad Please direct all scheduling inquiries to my office Follow me on twitter ®Ihsummers www.larrysummers.com Begin forwarded message: From: "Neff, Daniel A." < Date: July 29, 2015 at 3:10:10 PM EDT To: "Lawrence H. Summers" Cc: "Kim, Richard K." <I Subject: Fwd: Summers / DE Shaw Larry, >, "Lawrence H. Summers" Our lead regulatory partner, Richard Kim, believes that the question you asked me on Friday relates to amendments to the Investment Advisers Act made by Dodd-Frank. Richard 's view, as indicated below, is that that you should be OK so long as your advice relates to economic, finance or political matters and not to the purchase or sale of individual securities. Don't hesitate to contact Richard directly (or me, of course) if you wish to discuss further. Dan Sent from my iPad Begin forwarded message: From: "Kim, Richard K." <e Date: July 28, 2015 at 5:41:55 AM GMT+2 To: "Neff, Daniel A." Subject: Summers / DE Shaw mailto mailto: >> Dan - I looked at the question of whether the Dodd Frank amendments to the Investment Advisers Act should pose any issues for Professor Summers and don't think they do. The Investment Advisers Act requires registration with the SEC for any person who engages in the business of advising others as to the value of securities or the advisability of investing in or selling them as well as those who issue analyses concerning securities. Dodd Frank eliminated the private investment adviser exemption which previously exempted EFTA00673837 investment advisers with fewer than 15 clients who did not hold themselves out as investment advisers. The purpose was to sweep in advisers to hedge funds. Since Summers' business shouldn't fall within the scope of the definition of an investment adviser to begin with, the loss of the exemption shouldn't have any implications for him. Glad to discuss at your convenience. Richard Richard K. Kim Wachtell Ligon, Rosen & Katz Please be advised that this transmittal may be a confidential attorney-client communication or may otherwise be privileged or confidential. If you are not the intended recipient, please do not read, copy or re-transmit this communication. If you have received this communication in error, please notify us by e-mail ) or by telephone (call us collect at ) and delete this message and any attachments. Thank you in advance for your cooperation and assistance. www.wlrk.com EFTA00673838