NASAA Proposes State Registration for 3(c)(1) Fund Managers
NASAA, an organization of state securities agencies, has proposed a model state rule that would require state registration of venture capital funds and private fund advisers to 3(c)(1) funds with less than $150 Million in assets. The model rule only exempts private fund advisers qualified under Section 3(c)(7), which requires all investors to qualify as “qualified purchasers” under the Investment Company Act. Advisers to funds exempt from investment company registration because they have fewer than 100 holders would not be exempt from state adviser registration. Additionally, the model rule requires private fund advisers subject to SEC registration to file certain information with the states.