In two recent pronouncements, the SEC provided much-needed guidance on when a family office does not have to register as an investment adviser. In a recently-issued no-action letter, the SEC stated that it would not recommend enforcement action against a 3(c)(7) fund in which a fund managed by a family office invested, based on an investment in the family office fund by the non-family member executive director of the family office. In a roughly contemporaneous order granted to another family office, the SEC held that a family office did not have to register as an investment adviser where that family office provided services exclusively to a single family, was owned by the family and had a board of directors, the majority of which was comprised of family members.