Advisers relying on the Private Fund Adviser¹ or the Venture Capital Fund Adviser Exemption² (“ERA”), are exempt from registration but remain subject to certain reporting and compliance obligations.
|Exempt from Registration
Registration and exemption rules can be complex and application must be determined on a case-by-case basis, given an adviser’s specific facts and circumstances. Advisers who are exempt from registration with the SEC may still be subject to state registration requirements. Hardin works with you to assess your registration requirements and to identify exemptions that may be available.
Not Exempt from Regulation
ERA Compliance Navigator® Program
|program and adopt policies and procedures that address the firm’s regulatory obligations. Further, adopting certain best practices can help the ERA protect itself and its clients. Beyond their statutory obligations, ERAs should consider whether policies and procedures pertaining to the following topics should also be developed and implemented:
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¹The Private Fund Adviser Exemption is generally available to advisers that only manage private funds and have less than $150 million in assets under management.
²The Venture Capital Fund Adviser Exemption is generally available to investment advisers that solely advise venture capital funds.