Though minimally regulated, exempt reporting advisers are still subject to U.S. general securities laws, just like any other market participant. Many advisers also choose to implement certain compliance policies and procedures as a matter of best practices.
The SEC and some states offer exemptions from registration requirements for private fund managers and venture capital firms. However, claiming these exemptions can limit a firm’s advisory activities.
Greyline works closely with our exempt reporting advisers clients to navigate their options and create a scaled, nimble and practical compliance program. We also work with growing firms who anticipate interest from more sophisticated investors, and factor their diligence requirements into their compliance program. Our process includes:
- Analyzing the firm’s business model, strategies and growth goals
- Preparing and filing Form ADV Part 1
- Drafting custom policies and procedures
Latest Observations from OCIE on Private Fund Managers
Earlier this week, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert discussing deficiencies from recent routine examinations of private fund managers (“Advisers”). These are in