An investment adviser that is not required to register as an adviser with the Securities and Exchange Commission (“SEC”) or state regulator(s) if it meets certain qualifications, pays applicable fees, and reports public information through the Investment Advisor Registration Depository (“IARD”). Large Advisers (firms with $100M or more in regulatory Assets Under Management (“AUM”) that meet the private fund adviser or venture capital exemption requirements may register with the SEC as federally covered ERAs. Mid-Sized (firms with between $25M and $100M in regulatory AUM) and Small Advisers (firms with less than $25M in regulatory AUM) are generally required to register as state-covered Registered Investment Advisers (“RIA”) or if an exemption is available, a state-covered ERA. Certain states have adopted the federal rules allowing mid-sized or small advisers to rely on modified versions of the private fund adviser or venture capital adviser exemption.
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