Reporting Obligations for Exempt Reporting Advisers

March 1, 2012

The Form ADV Part 1A filing deadline is approaching for advisers who are relying on the private fund adviser exemption or the venture capital adviser exemption (collectively, “Exempt Reporting Advisers”) from SEC registration. As discussed previously in our January 26, 2012 memorandum, an Exempt Reporting Adviser must submit its initial Form ADV by March 30, 2012, provided that a new investment adviser formed after January 1, 2012 must submit its initial Form ADV within 60 days of first relying on the private fund adviser exemption or venture capital adviser exemption.1

If you have any questions about the reporting obligations for Exempt Reporting Advisers, please contact an attorney in the Investment Management Group at Seward & Kissel LLP.


1 In order to submit Form ADV through the IARD, Exempt Reporting Advisers must first establish an IARD user account and deposit funds into its financial account in order to cover an initial set-up fee and any fees associated with state Notice Filings or state registrations. Depending on the method of payment used, it may take up to two business days in order to fund an IARD account.