b'Most fund of funds issuers will try to qualify under this exception.Third, You Must Comply With The Investment Advisers Act of 1940 IfyouareadvisingyourCompanysinvestorsonthepurchaseof securities (traditional fund of funds model), and you dont qualify for the Real Estate Company exception to the Investment Company Act, you fall within the definition of an investment adviser. This means you must now complywithTheInvestmentAdvisersActof1940(AdvisersAct).A summaryofcompliancerequirementsfortheAdvisersActisprovided below:Federal Investor Adviser Requirements Investment advisers must register with either federal or state securities authorities, depending on the amount of assets under management. Small advisers, with less than $25 million in regulatory assets under management (RAUM), and mid-sized advisers, with $25 million to $110 million in RAUM, generally may only register with state securities authorities. A private fund adviser who is exempt from registration under the so-calledsmalladviserexemption,underSection203A(a)(1)(A)ofthe Investment Advisers Act, may nonetheless be required to file a truncated FormADVbecausesuchfilingisnecessarytotakeadvantageofthe NASAA Registration Exemption for Investment Advisers to Private Funds Model Rule. The small adviser exemption is actually a provision of the Investment Advisers Act that prohibits any adviser (with a few exceptions) with assets under management of under $25 million from registering with 142'