No. Blue sky filings are state-level securities filings tied to your fund offering, not to your adviser registration status. ERA status exempts you from full SEC registration as an adviser, but it does not affect your state securities filing obligations for each fund.
After you file Form D with the SEC, most states require a corresponding notice filing (commonly called a "blue sky" filing) in every state where you have investors or plan to sell securities. The timeline varies by state, but most require the filing within 15 days of the first sale to a resident of that state. Fees range from $100 to $500 per state, and most filings go through the Electronic Filing Depository (EFD).
Missing blue sky filings can result in state-level penalties and may complicate future fundraising in those jurisdictions. When you take on a new investor from a state you have not previously filed in, you need to make a new blue sky filing for that state. Keep a tracking list of which states you have filed in for each fund.
See Form D and Blue Sky Filings.
This content is for informational purposes only and does not constitute legal, tax, or compliance advice. Consult qualified counsel for guidance specific to your situation. Capital Company is not a law firm and does not provide legal advice.