What Is the De Minimis Exemption for Investment Advisers?

The De Minimis exemption exists to spare advisers from the burden of registering in every state where they happen to have one or two incidental clients, often the result of a client relocating rather than active solicitation in that state. Firms relying on the de minimis exemption still need to track their client count by state carefully, since exceeding the threshold, even by gaining a single additional client in a given state, can trigger a registration requirement there.

Some states apply the de minimis exemption differently or have their own specific thresholds and conditions, so firms operating near the edge of the standard threshold in any state should confirm that state’s exact rule rather than assuming a uniform national standard.