Exempt Reporting Adviser
A private fund adviser exempt from SEC registration but still filing reports.
What is Exempt Reporting Adviser?
Advisers solely to venture capital funds, and advisers solely to private funds with less than $150 million of assets under management in the US, are exempt from SEC registration. They still file an abbreviated Form ADV with the SEC, and states may require filings too.
Exempt Reporting Adviser: a worked example
An adviser managing only two private funds totaling $90 million files as an exempt reporting adviser.
More terms in Uniform Securities Act & Registration
Uniform Securities Act (USA)
The model state securities law most states' 'blue sky' statutes are based on.
State Securities Administrator
The official or agency that enforces a state's securities act.
Person (USA Definition)
Anyone who can be held legally responsible - individuals and organizations.
Investment Adviser (USA Definition)
Advises on securities, as a business, for compensation.
Excluded from the Investment Adviser Definition
Banks, incidental professionals, broker-dealers, and publishers are not advisers at all.
Exemptions from State Adviser Registration
An adviser with no office in the state and only institutional or very few clients there.
De Minimis Exemption
No place of business in the state and fewer than 6 clients there in 12 months.
Federal Covered Adviser
An adviser registered with the SEC rather than the states.
All Uniform Securities Act & Registration terms · Full glossary