More Screen Time: SEC Adopts Amendments to Internet-Only Investment Adviser Exemption

On March 27, 2024, the Securities and Exchange Commission (“SEC”) announced amendments to the rule that allows internet-only investment advisers to register with the SEC (the “Rule”).[1] The amended Rule eliminates the current Rule’s de minimis exception approach[2] and requires internet-based investment advisers relying on the Rule to:


  • provide investment advisory services exclusively to internet-based clients (i.e., internet-based investment advisers relying on the amended Rule cannot have clients outside of its internet-based services);
  • maintain – at all times – an operational interactive website through which the adviser provides its investment advisory services to clients; and
  • make disclosures in its Form ADV that the internet-based investment adviser maintains an operational interactive website and is eligible to file under the Rule.[3]


Investment advisers relying on the Rule must comply with the amendments by March 31, 2025.


If you have any questions about the Rule or the regulation of investment advisers generally, please feel free to contact us.


By the Investment Management and Broker-Dealer Team at Kilpatrick Townsend & Stockton


This content is provided by Kilpatrick Townsend & Stockton LLP for informational purposes only and is not intended to advertise our firm’s services, to solicit clients, or to provide legal advice.  Viewers should not rely on the posted materials as advice about specific legal problems.  Such advice can be rendered only by competent counsel familiar with the particular facts and circumstances involved.  Posting and viewing of the materials on our website or in printed form is not intended to constitute the rendering of legal advice or to create an attorney-client relationship with the viewer.  If Kilpatrick Townsend & Stockton LLP does not already represent you, and you send us an e-mail, your e-mail will not create an attorney-client relationship and will not be treated as privileged or confidential.




Attorney Advertising – Kilpatrick Townsend & Stockton LLP, 1100 Peachtree Street NE, Suite 2800, Atlanta, GA 30309 | 404-815-6500.


For more information, please refer to our Terms of Use and Privacy Policy.

[1] 17 CFR 275.203A-2(e); SEC Press Release, SEC Adopts Reforms Relating to Investment Advisers Operating Exclusively Through the Internet, March 27, 2024, available at

[2] The current Rule allows internet-only investment advisers to provide investment advice to fewer than 15 non-internet clients during the preceding twelve months.

[3] SEC Fact Sheet, Internet Adviser Registration Reforms, March 27, 2024, available at

Knowledge assets are defined in the study as confidential information critical to the development, performance and marketing of a company’s core business, other than personal information that would trigger notice requirements under law. For example,
The new study shows dramatic increases in threats and awareness of threats to these “crown jewels,” as well as dramatic improvements in addressing those threats by the highest performing organizations. Awareness of the risk to knowledge assets increased as more respondents acknowledged that their