Our recommendation is to check with your counsel on this matter, but happy to provide our securities counsel's view relating to exempt reporting adviser.
If you are providing investment advice to a "private fund" for a fee, you would have to register as an exempt reporting adviser or as a registered investment adviser. That would probably be the case of many fund managers and syndicate leads.
For the fund managers that do not have an ERA or RIA, we offer an "adviser service", which is offered through one of our affiliate entities that is a registered ERA. Here is a link to materials pertaining to our adviser service.