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SEC Adopts Reforms Relating to Investment Advisers Operating Exclusively Through the Internet

May 20, 2024

On March 27, 2024, the Securities and Exchange Commission adopted amendments to the rule permitting certain internet investment advisers to register with the Commission (the “Internet Adviser Exemption”).[1] The amendments will require an investment adviser relying on the Internet Adviser Exemption to have at all times an operational interactive website through which the adviser provides digital investment advisory services on an ongoing basis to more than one client. The amendments will also eliminate the current rule’s de minimis exception by requiring an internet investment adviser to provide advice to all of its clients exclusively through an operational interactive website and to make certain corresponding changes to Form ADV.


An adviser relying on the Internet Adviser Exemption must comply with the rule, including the requirement to amend their Form ADV to include a representation that the adviser is eligible to register with the Commission under the internet adviser exemption, by March 31, 2025. An adviser that is no longer eligible to rely on the amended exemption and does not otherwise have a basis for registration with the Commission must register in one or more states and withdraw its registration with the Commission by filing a Form ADV-W by June 29, 2025.



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