ADV Filings for Exempt Reporting Advisers

Although many advisers to private funds will be required to register as a result of the Dodd-Frank Act, some will be exempted from registration. The SEC refers to these advisers as exempt reporting advisers. Even though exempt reporting advisers are not required to register with the SEC, they are subject to strict reporting, recordkeeping, and other compliance obligations.

Exempt reporting advisers include:

  • Advisers solely to venture capital funds
  • Advisers solely to private funds with less than $150 million in assets under management in the U.S.

Although exempt reporting advisers file the same Form ADV as registered investment advisers, they only need to respond to certain items and questions. RIA Compliance Group can help exempt reporting advisers with their initial and annual Form ADV filings and the preparation of privacy policies and procedures.

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