No. Federal ERA status does not preempt state law. If you have a place of business in a state, you likely need notice filings or full state registration with that state's securities regulator, depending on the state.
Most states offer some form of exemption or notice filing process for SEC-registered or SEC-exempt advisers, but the rules vary significantly. Some states (like New York) have a straightforward notice filing through IARD. Others (like Delaware, Washington, and California) have exemptions with specific conditions that may not cover all fund structures. A few states require full state registration even for federal ERAs who maintain a physical office there.
The most common mistake is assuming your federal ERA status is all you need. Check the requirements for every state where you have a physical office or a significant number of investors. State fees are typically modest ($100 to $300 per year), but missed state filings can create problems if you later need to register or if a state regulator audits your firm.
See State Investment Adviser Registration for Private Fund Managers.
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