Allocations recommends that each fund manager consults with their legal counsel regarding Advisor compliance. Generally, if a fund manager is providing investment advice to a "private fund" for a fee, the manager would have to register as an Exempt Reporting Adviser or as a Registered Investment Adviser.
For fund managers that do not have an ERA or RIA, Allocations offers an Exempt Reporting Adviser service. Here is a link to materials pertaining to our adviser service.