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Are there any reporting requirements for exempt advisers?

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Are there any reporting requirements for exempt advisers?

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Advisers that rely on the venture capital exemption and the private fund with less than $150 million in assets under management exemption are considered “exempt reporting advisers,” are still subject to certain reporting requirements and may be subject to state reporting requirements. These advisers will be required to file the same registration form (i.e. Form ADV Part 1) as registered investment advisers. However, they will not be required to complete the entire Form ADV Part 1. Rather, they will have to provide basic identifying information, information about the fund and any conflicts of interest that could present risks to the fund’s clients, and include any disciplinary history. These reports will need to be filed through the SEC’s Investment Adviser Registration Depository (IARD). The first report was due in the first quarter of 2012.

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