There are two exemptions that advisers can use to claim exempt reporting adviser (“ERA”) status. These include: the Private Fund Adviser Exemption; and the Venture Capital Fund Adviser Exemption. If either exemption becomes inapplicable, the adviser is no longer eligible for the private fund adviser exemption and needs to register as a registered investment advisor (“RIA”) firm with the appropriate regulator.
To help ERA’s better understand the transition process, we’ve outlined the conditions which would require an ERA to register as an RIA, and the steps to take to register with either the state or federal regulators.
Contact us if you any questions about our private fund adviser compliance software.