An exempt reporting adviser is an investment adviser that is not required to register with the SEC or with state securities authorities but is required to file an annual report via a Form ADV. You can learn more about this requirement in the SEC’s “VC Exemption,” Rule 203(l)-1 of the Advisers Act.
If you are advising your investors (or LPs) and taking carry, you may need to file a Form ADV. You have 60 days from the date of your first securities offering to do so.