An adviser that would otherwise have to register in fifteen or more states because of the $100 million AUM threshold may register directly with the SEC instead, so multi-state registration burden operates as an escape hatch to federal oversight.
Source quote, verbatim
However, should the $100 million AUM threshold result in an adviser's registration with fifteen or more states, the adviser is allowed to register directly with the SEC.86
Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268
Holds when
advisers whose state registrations would reach fifteen or more states
Classification
conditionsupport: assertedsecurities-law
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