... Implementing Adopting Release, infra note 32, at section II.A 26 Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers with Less than $150 Million in Assets under Management, and Foreign ... shareholders at the demand of the venture capital fund1 97 or for returning capital to the fund, 198 and not, for example, define leverage to include indebtedness incurred to pay for a qualifying portfolio ... support for a definition that is no broader than necessary in order to ensure that only advisers to venture capital funds, and not other types of private funds, are able to avoid the new mandatory...