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All registered investment advisers—including exempt reporting advisers—are required to file various regulatory and compliance filings throughout the year. THE MOST IMPORTANT OF THEM IS THE ANNUAL UPDATING AMENDMENT ON FORM ADV. The various filing requirements differ slightly for SEC-registered investment advisers, state-registered investment advisers and exempt reporting advisers. The specific requirements are summarized in this brief overview.

A question we are frequently asked is whether a fund manager may hire a person to solicit investors for his fund. The question arises when the fund manager wants to hire an unregistered person to introduce investors, and that person seeks to obtain payment based on the successful introductions.

As registered investment advisers (“RIAs”) attempt to grow their businesses, they often consider whether to use third-party solicitors. RIAs must take care to understand the compliance obligations they will face when they choose to enter into a solicitation arrangement.