Within 60 days of your first fund's initial close. The clock starts when you close your first investor and accept capital commitments, not when you form the entity, begin marketing, or sign your LPA.
Before you can file, you need an IARD account and a CRD number. Setting up your IARD account can take a few business days, so do not wait until close to start the process. You will also need your fund's legal entity details (EIN, formation state, fiscal year end) and information about your service providers (auditor, legal counsel, prime broker if applicable).
Missing the 60-day deadline means you are technically operating as an unregistered adviser. While the SEC does not automatically penalize late filings for ERAs, the gap is visible in your public record. Institutional LPs check IAPD during diligence, and a late initial filing raises questions about your compliance awareness.
See Form ADV for Private Fund Managers: The Complete ERA Filing Guide.
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.