Yes. Managing a private fund (VC, PE, hedge fund, or SPV) makes you an investment adviser under federal law. Size does not exempt you from filing. What size affects is whether you file as a fully Registered Investment Adviser or as an Exempt Reporting Adviser with lighter requirements.
Most emerging managers qualify for ERA status under either the venture capital fund adviser exemption (Section 203(l), no AUM cap, but every fund must qualify as a VC fund) or the private fund adviser exemption (Section 203(m), any fund type allowed, but AUM must stay below $150 million). ERA status reduces your filing burden to a subset of Part 1A and Schedule D, with no brochure or Form CRS requirement.
A common mistake is assuming that a single small fund does not trigger any obligation. It does. Your initial Form ADV filing is due within 60 days of your first fund's initial close. Missing this deadline creates a gap in your public record that institutional LPs will notice during diligence.
For the full guide, see Form ADV for Private Fund Managers: The Complete ERA Filing Guide.
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