An exempt reporting adviser is an investment adviser that is not registered with the SEC, but is subject to certain SEC reporting, recordkeeping, and other obligations. For example, an exempt reporting adviser is required to report some information on Form ADV but is not required to complete all of Form ADV like registered advisers.
An exempt reporting adviser can only provide investment advice to private funds, such as hedge funds, venture capital funds, and private equity funds. Private funds generally pursue more flexible investments and strategies than registered investment companies, like mutual funds and ETFs, which may increase the risk of investment losses. They are not subject to the numerous regulations that apply to mutual funds and ETFs for the protection of investors. Depending on how the fund is structured, an investor in the type of funds advised by exempt reporting advisers typically needs to be an accredited investor or qualified purchaser. An accredited investor or a qualified purchaser must have a certain level of income or assets or meet other professional criteria.
Investors should be wary of a purported ERA that offers investment advice directly to individual investors or claims to be registered with the SEC. The SEC’s Office of Investor Education and Assistance has issued an investor alert warning investors that scammers are using SEC ERA filings to create a false impression of legitimacy and to lure investors into scams.
You can find information about a specific exempt reporting adviser, including its latest Form ADV, using the Check Out Your Investment Professional tool on Investor.gov. For information on how to use our tool, please read: How to Use the Investment Professional Search Tool on Investor.gov.
