EPISODE · Jun 11, 2026 · 7 MIN
Exempt Reporting Adviser Status for Reg D Fund Sponsors
from Syndication Attorney Field Notes with Tilden Moschetti · host Tilden Moschetti
=Short legal field notes from syndication attorney Tilden Moschetti for sponsors raising capital through Regulation D offerings. In this episode: why a clean Rule 506 capital raise does not answer whether the management company may have exempt reporting adviser status questions. Tilden explains the separation between the Securities Act and the Investment Advisers Act, how the $150 million RAUM threshold functions for private fund sponsors, and why uncalled capital commitments and state Blue Sky adviser rules can affect a management company's regulatory posture.Also see: Exempt Reporting Adviser Status for Reg D Fund Sponsors at https://www.moschettilaw.com/exempt-reporting-adviser-private-funds
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What this episode covers
In this episode, syndication attorney Tilden Moschetti explains why a Regulation D private placement covers the capital raise, but the private fund management company may still need to evaluate exempt reporting adviser status.
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Exempt Reporting Adviser Status for Reg D Fund Sponsors
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