No. Form D is a securities offering filing, not an adviser registration filing. ERA status exempts you from full RIA registration, but it has no effect on your obligation to file Form D for each fund or SPV that sells securities under Regulation D.
Form D is due within 15 days of the first sale of securities in your fund (typically your first close). You file it through EDGAR, not IARD. Each fund, SPV, or co-investment vehicle that issues securities needs its own Form D. You must also file an amendment to Form D annually and whenever there is a material change to the offering.
Missing the Form D deadline does not automatically void your Regulation D exemption, but it can create problems. Some states treat a missing or late Form D as a violation that triggers additional filings or penalties. More practically, LPs and their counsel check EDGAR for your Form D during diligence, and a missing filing raises questions.
See Form D and Blue Sky Filings.
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