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by jakequist 2640 days ago
tl;dr - A16Z is reclassifying themselves as an "investment advisor", which will allow them to make riskier bets (crypto, real estate, etc). They'll still invest in startups like any other VC firm.
8 comments

I feel like there's some misunderstanding of what these terms are. All VCs are investment advisors (either Exempt Reporting Advisors or Registered Investment Advisor depending on assets under management and investment types).

The article is vague in what it actually means, but it sounds to me like A16Z is going through the process of giving up its VC exemption to the Investment Advisers Act and registering as a RIA. It could also mean they're registering as a broker-dealer and getting its relevant employees licensed as such (e.g. Series 65)

Source: I run a VC firm.

Here is some more info: https://www.strictlybusinesslawblog.com/2018/05/31/the-ventu...

it's renouncing the IAA exception, registering as RIA, i confirmed with the Forbes journalist yesterday
What is an RIA?

I know what these things are: hedge fund, private equity, wealth management, venture capital.

Which is A16Z now closest to? Or is there a class of financial firm I'm not aware of?

Edit: I'm also curious, does this place any material restrictions on their startup investment activity?

Registered Investment Advisor. Legal entity that allows you to manage other people's money.

VCs, hedge funds and wealth management tend to be RIAs. Private Equity I'm unsure. Wealth managers are all either RIAs, brokers, or banks.

The article is unclear. A16Z are forgoing a certain exception that VCs have, I'm not sure what their legal structure was beforehand.

You can look up all RIAs on the SEC website https://adviserinfo.sec.gov/

Yes, that's the interesting thing here, so we've put it in the title above. Hopefully that will nudge the discussion to be more specific and less lame.
thanks dang! You rock
A totally n00b question.

Isn't VC the person with the money, so they are more in control.

While an "investment advisor" is just advising or suggesting where the money can be put for maximum returns like an investment advisor in banks? So, presumably less in control.

I don't understand why a title change was needed. Any technical or legal reasons?

From 30k ft--in the financial industry, the VC title afforded a carve out from SEC oversight if its business was focused around certain qualifications (e.g., invested primarily in new-early stage private companies).

This classification, in turn, also limits what an entity with a VC status can ultimately do and invest in.

In this case, a16z has ambitions that outstrip the limited definition of VC in the eyes of the SEC. Under their new classification, they still have the monies as an 'investment advisor' but aren't hamstrung on what they can invest in. It will, however, change the way they will be required to operate due to new regulations that come with the investment advisor classification.

Related, an article from the NVCA on the subject from December. [0]

[0] https://nvca.org/blog/need-update-definition-vc-heres/

wpennington answered the overall question better than I could, but one clarification on this:

> Isn't VC the person with the money, so they are more in control.

Most of the money VCs invest isn't their own. The money is allocated by "limited partners" (entities such as pension funds, endowment funds, sovereign wealth funds, rich individuals/families), and the VC firm uses their expertise and network to invest the money on the LPs' behalf, in exchange for a "management fee" and a cut of the returns.

The VC firm's partners do usually invest some of their own money (to have some "skin in the game"), but it's a token amount compared to the outside money they're investing.

Due to their role as custodians for huge amounts of other people's money (which, particularly in the case of pension funds, ultimately belongs to ordinary people), there are substantial regulatory controls and requirements.

Totally--and this is a really good point to clarify, especially if one would like to understand more broadly how VC works. I intentionally abstracted the "where does the money come from" in my original reply to focus on the classification itself, but that admittedly left the comment lacking this useful context. LP and venture dynamics are both interesting and important to understand the full picture.

> Most of the money VCs invest isn't their own.

To underscore tomhoward's point--VCs are largely (already) stewards of other people's money (their LPs). So while they are set up to be "the person with the money" from the market's perspective (e.g., if you are looking to get your company funded), they are acting as investment advisors (e.g., where and how to spend the fund's money--and by extension the LP's money--for a fee). Albeit with a specific legal exemption set forth in the Investment Advisers Act that governs certain activity depending on how they are registered* (this is what is changing for a16z). No matter how they are registered, they do have compliance requirements as custodians of other people's money.

*Under the Investment Advisory Act, they can be registered as: (1) ERA - exempt reporting advisor (what we are referring here as a VC in the traditional sense), or (2) RIA - registered investment advisor.

As it relates to a16z, they are giving up their IAA exemption as a fund (registering as an RIA vs ERA). No need to get into why that matters again (see other posts that have already addressed it well). The point being, VCs are already in many ways "investment advisors" as custodians of other people's capital (and sometimes their own) through their funds and they have compliance requirements, just different depending on how they are registered.

> Isn't VC the person with the money, so they are more in control.

They are the person with other people‘s money.

> While an "investment advisor" is just advising or suggesting where the money can be put for maximum returns like an investment advisor in banks?

That is basically what they are doing. Making dcisions where to invest their client’s money.

They will or already did?

Cryptocurrency prices jumped 20% because of a well executed 100M order

The article reads like advertisement for A16Z.
But imagine, if you are a VC and you invest in a Brothel then you risk your reputation etc...

But if you act like an advisor for Mr. Evil Money, then it's not you who is on the hook, right?

Basically, it means they want to do something more aggressive and risky and maybe the opportunities in VC space are disappearing.

still surprised I haven't seen any revenue shares of those kind of businesses on the blockchain, ever since 2013's crypto-securities bonanza

either the revenues are that high such that nobody has a desire to sell some of the company, or there is a language barrier in the host jurisdictions where these can legally operate, or nobody has considered it as the incumbents are so comfortable with their licensing/turf that they don't need to change a thing

the technology is so much better now than 2013 and nobody calls them crypto-securities anymore, it is such an obvious use case for price discovery, liquidity, and acceleration of public policy

> crypto, real estate

Crypto maybe, not real estate doesn't sound as risky as startups.

Maybe it depends on what type of real estate.
> which will allow them to make riskier bets (crypto

Sounds like they'll blow up their wallet next