Blue sky filings for your fund

Updated 1 month ago by Sanjay Vora

With Regulation D funds (both 506c and 506b), states require a blue sky filing to be completed the first-time securities are sold to an investor in that state. The below table provides the costs associated with those filings. The filings needs to be done within 15 days of taking capital from an investor. Avestor can handle these filings for you at a normal service charge. The below table provides a listing of the fees that states charge.

State
Filing Fee
State
Filing Fee
State
Filing Fee

Initial EFD Fee

$160

Kentucky

$250

Oklahoma

$250

Alabama

$300

Louisiana

$300

Oregon

$250

Alaska

$600

Maine (manual)

$300 (manual)

Pennsylvania

$525

Arizona

$250

Maryland

$100

Puerto Rico

$350-$1500A

Arkansas

$100-$500

Massachusetts

$250-$750

Rhode Island

$300

California

$300

Michigan

$100

South Carolina

$300

Colorado

$50

Minnesota

$100-$300

South Dakota

$250

Connecticut

$150

Mississippi

$300

Tennessee

$500

Delaware

$200-$1000

Missouri

$100

Texas

$0-$500

D.C.

$250

Montana

$200-$1000

Utah

$0-$100

Florida

No filing req.

Nebraska

$200

U.S. Virgin Isl

$1500

Georgia

$250

Nevada

$500

Vermont

$600

Guam

$500 (manual)

New Hampshire

$500

Virginia

$250

Hawaii

$100

New Jersey

$500

Washington

$300 **

Idaho

$50

New Mexico

$350

West Virginia

$125

Illinois

$100

New York

$1200

Wisconsin

$200

Indiana

$0

North Carolina

$350

Wyoming

$200

Iowa

$100

North Dakota

$100

Kansas

$0

Ohio

$100

A – 0.20% of offering size in Puerto Rico; min $350, max $1500

**Reg D funds are considered pooled investments by the SEC if the fund does not own the assets. In that case, Avestor recommends sponsors do not take investors in the state of Washington. Washington State rules have a restriction that advisers of pooled investment funds register as an Investment Adviser as soon as they have more than 5 investors in that state. To verify if your fund is considered a pooled investment, you can look up your fund at SEC.gov | Company Search Page.

Although most states are one-time fees, the following states request annual renewals:

  • Alaska, Arkansas, Illinois, Minnesota, Mississippi, Montana, Nevada, NY (4 years), North Dakoka, Pureto Rico, South Carolina, Tennessee, USVI, Vermont

Avestor Service Fees

Avestor handles blue sky filings at nominal charge compared to attorneys performing the services. We do require all state filing fees and our service fees to be paid up front since we must pay the states at the time the filing is completed.

Item
Service Fee
Description

Initial EFD Setup

No charge

Avestor sets up your fund in the NAASA database to accept blue sky filings.

Electronic Filing Fees / state

$50

Avestor files the blue sky filing for each state when you get your first investor in that state.

Manual Filing Fees / state

Attorney fees of up to $500

A few states continue to use manual filings – Maine, Guam. Given the complexity of these filings, Avestor will request your attorney to file these manual filings. Service fees are attorney dependent.


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