Investment Adviser Registration

If you raise money and deploy it into other operators' deals, you may be operating as an investment advisor under federal or state law. The Investment Advisors Act of 1940 defines an investment advisor as anyone who, for compensation, is in the business of advising others about securities. Every state has similar rules. When you run a fund of funds, that's exactly what you are doing. You are selecting which securities. which operator's offerings that your investors' money goes into. You're compensated for that selection. That's the core function of the model. Whether registration is actually required depends on your client count, assets under management, and whether any state or federal exemptions apply. But it's a real question, and it needs a legal analysis, not an assumption that it doesn't apply because the operator's deals are real estate. or because your coach didn't bring it up. Most coaches who teach this model present it as a Reg D filing with lighter operations. The Investment Advisors Act never comes up. Operating as an unregistered investment advisor when registration is required is a separate federal or state violation. The full compliance picture for a fund of funds and who this structure actually works for is in the long form. See the link in the bio.