We assist registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) with their initial and ongoing compliance obligations. The jurisdictional parameters between federal and state oversight of registered investment advisers were significantly altered post-Dodd-Frank, creating an even greater need for managers to engage qualified counsel to help them navigate their initial registration / notice filing requirements, especially as state securities commissioners continue to amend their rules regarding registered investment advisers and available exemptions from registration in response to the changed federal requirements. Our registered investment adviser / exempt reporting adviser services cover all aspects of the registration / notice filing process and include:
- hedge fund and separate managed account managers regarding their investment adviser registration requirements and available exemptions from registration, including private fund adviser exemptions, venture capital exemptions, etc.
- Registering managers as RIAs at the state and federal level, including preparing and filing Form ADV Parts 1 and 2 on behalf of the adviser and liaising with the Securities and Exchange Commission or applicable state securities commission
- Notice filing advisers as ERAs at the state and federal level
- Preparing initial compliance documentation for the adviser, including a firm compliance manual, privacy notice, etc.
- Advising the principals regarding applicable proficiency requirements
- Advising RIAs and ERAs regarding custody requirements, performance-based compensation rules, client net worth and qualification requirements, etc., as well as advertisements and other promotional materials, including rules regarding performance reporting
- Preparing an investment advisory agreement for the adviser and other client agreements, as needed
- Assisting RIAs and ERAs with ongoing compliance obligations, including preparing and filing Form ADV annual amendments, updating firm brochures and privacy notices, amending investment advisory and other client agreements, etc.
If you have any questions regarding our registered investment adviser or exempt reporting adviser services or would like to schedule a free consultation, please do not hesitate to contact us.