How to Start a Hedge Fund in New Jersey

The $100 LLC, the $750 notice filing, the private fund adviser exemption New Jersey never adopted, and the per owner tax that surprises fund managers.

13 min read
LLC Formation
$100
per LLC, $75 annual report
506 Notice Filing
$750
via EFD, 15 days after first sale
Adviser Exemption
Not adopted
5 client de minimis instead
Investors
Non-accredited OK
up to 35 under Rule 506(b)

This guide is for educational purposes only and does not constitute legal or financial advice. Consult qualified professionals before making any decisions.

New Jersey makes the corporate mechanics cheap and fast. A Certificate of Formation costs $100 per LLC, cut from $125 on July 1, 2026, online filings generally process in about a business day, and there is no publication requirement. The two entities behind a typical fund, the fund LLC and the management company LLC, cost $200 in state fees combined.

The securities side asks more. A Rule 506 offering needs a $750 notice filing through the NASAA Electronic Filing Depository no later than 15 days after the first New Jersey sale. And on the adviser side, New Jersey never adopted the NASAA model private fund adviser exemption. Unless you stay within the 5 client de minimis in N.J.S.A. 49:3-56(g), you register as an investment adviser with the Bureau of Securities.

There is also a tax rule worth budgeting for: a partnership with more than two owners and New Jersey source income or loss pays $150 per owner, every year. This guide walks the full path, with the statute behind each requirement.

Five steps to launch in New Jersey

1

Generate Documents

Free on Hedgia
$0
Same day

Every fund needs offering documents before it can take a dollar. Hedgia generates them at no cost, whether or not you launch on the platform.

Offering circular describing the strategy, fees, and risks
Operating agreements for the fund LLC and the management company LLC
Subscription documents investors sign to commit capital
Free to generate even if you never subscribe
2

Create LLCs

$200
About 1 business day

Two entities: a management company LLC that acts as manager, and the fund LLC investors buy into. Both file a Certificate of Formation with the Division of Revenue and Enterprise Services.

$100 Certificate of Formation per LLC on the official DORES fee schedule
Online filings through njportal.com generally process in about 1 business day; expedited service runs from $50 for same day to $1,000 for processing in 1 hour
EINs obtained from the IRS for both entities
$75 annual report per LLC, filed online, due the last day of the anniversary month
3

Create Accounts

$750
Days

File Form D with the SEC, make the New Jersey notice filing, and open the fund's bank account. Hedgia prepares and submits the filings at your direction and sets up banking through Axos Bank.

Form D filed with the SEC no later than 15 days after the first sale
New Jersey notice filing made through the NASAA Electronic Filing Depository with a $750 fee, due no later than 15 days after the first sale in New Jersey
Amendments filed through EFD within 30 days of any change to the Form D information
Fund bank account opened through Axos Bank
4

Invite Investors

$0
Ongoing

Investors onboard through the fund's portal: identity checks, accreditation status, subscription documents, and wires into the fund account.

Unlimited accredited investors under Rule 506(b)
Up to 35 non-accredited purchasers per offering, each with the knowledge and experience to evaluate the investment
Subscription documents signed electronically
Capital wired directly to the fund's bank account
5

Start Your Fund

$89/month*
Ongoing

Once capital lands, the ongoing work is administration: NAV, fees, investor reporting, and tax documents. That is the part the subscription covers.

$89/month includes 3 manager seats
NAV tracking, management and performance fees, investor reporting
K-1 preparation each tax year
0.2% of AUM above $1 million, capped

* $89/month includes 3 manager seats. Additional seats $30/month each. Plus 0.2% of AUM above $1 million, capped.

$950
Total Setup Cost
State fees: two LLCs at $100 each plus the $750 notice filing
1 to 2 weeks
Time to Launch
$89/mo
Ongoing Cost
Software. State adds $75 per LLC annual report

New Jersey requirements at a glance

Formation: $100 Certificate of Formation per LLC with the Division of Revenue and Enterprise Services. $75 annual report due the last day of the anniversary month. No publication requirement.
Offering filings: Rule 506 securities are federally covered, so New Jersey cannot require registration or merit review. It requires a notice filing: Form D through EFD with a $750 fee, no later than 15 days after the first sale in the state (N.J.S.A. 49:3-60.1(b)).
Adviser registration: No private fund adviser exemption exists in New Jersey. A manager with more than 5 New Jersey resident clients in 12 months registers with the Bureau of Securities: $550 per year plus $210 per representative.
Investors: Rule 506(b) permits unlimited accredited investors and up to 35 non-accredited purchasers per offering. No general solicitation.
Audits: Rule 506(b) does not itself mandate audited fund financials. In many states an audit condition comes with the private fund adviser exemption; New Jersey has no such exemption, so no exemption conditioned audit applies.
Taxes: A partnership with more than two owners and New Jersey source income or loss owes $150 per owner per year, capped at $250,000. Hedge fund status limits state tax exposure for nonresident investors.

The law behind each requirement

Rule 506(b): the federal private placement exemption

Nearly every small fund raises under Rule 506(b), an exemption from Securities Act registration. Securities sold under Rule 506 are covered securities under Securities Act Section 18(b)(4)(F), which blocks states from imposing registration or merit review on the offering.

  • Unlimited accredited investors, plus up to 35 non-accredited purchasers per offering who have the knowledge and experience to evaluate the investment
  • No general solicitation or advertising
  • Form D filed with the SEC no later than 15 days after the first sale
  • States may still require a notice filing, a fee, and consent to service of process
Securities Act § 4(a)(2); Rule 506(b), 17 C.F.R. § 230.506(b); Section 18(b)(4)(F)

The New Jersey notice filing for Rule 506 offerings

New Jersey requires notice of a Rule 506 offering. This is a notice filing for a federally covered security, not a state registration and not state approval of the offering.

  • File Form D through the NASAA Electronic Filing Depository no later than 15 days after the first sale in New Jersey, with the $750 fee paid through EFD
  • EFD is mandatory. An issuer unable to use it must contact the Bureau immediately and may be permitted a manual filing, which requires a manually signed and notarized Form U-2/U-2A consent to service of process
  • Amend through EFD within 30 days of any change to the information reported on Form D; the 2014 order lists no separate amendment fee
  • No fixed late filing penalty appears in the statute or rule. The bureau chief may issue a stop order suspending the offer and sale of the security for noncompliance (N.J.S.A. 49:3-60.1(d))
N.J.S.A. 49:3-60.1(b); N.J.A.C. 13:47A-7.10; Bureau Chief Order of December 12, 2014

Investment adviser registration with the Bureau of Securities

Acting as an investment adviser in New Jersey without registration is unlawful unless an exemption or exclusion applies. Managing a fund for compensation is advisory activity, so every New Jersey manager has to answer this question.

  • Register through IARD. The Bureau's fee is $550 for the adviser, initial and annual renewal, plus $210 per investment adviser representative
  • Registrations expire December 31 each year
  • Representatives must pass the Series 65, or the Series 66 together with the Series 7
  • SEC registered advisers do not register with the state, but must file their SEC documents with a fee and consent to service of process before conducting advisory business in New Jersey (N.J.S.A. 49:3-56(n))
N.J.S.A. 49:3-56(a), (i), (n); N.J.A.C. 13:47A-5.1; N.J.A.C. 13:47A-4.3

The de minimis exemption, and the exemption New Jersey does not have

New Jersey never adopted the NASAA model private fund adviser exemption, and its regulations at N.J.A.C. 13:47A contain no substitute. The only practical exemption for a small manager is the de minimis written into the statute. Federal exempt reporting adviser status under Advisers Act Section 203(m) does not excuse state registration.

  • Exempt with not more than 5 clients who are New Jersey residents during any period of 12 consecutive months, whether or not you have a place of business in the state
  • Institutional clients listed in N.J.S.A. 49:3-49(g)(2)(vi), including banks, insurance companies, investment companies, and other advisers, do not count toward the 5
  • No primary source states whether a private fund counts as one client for this test. Practitioners treat each fund as one client; confirm the counting with counsel or the Bureau before relying on it
  • A manager who cannot fit within the de minimis registers with the Bureau
N.J.S.A. 49:3-56(g); N.J.S.A. 49:3-49(g)(2)(vi); N.J.A.C. 13:47A

Section 3(c)(1): staying outside the Investment Company Act

Section 3(c)(1) excludes the fund from the definition of investment company. It is an exclusion from the definition, not an exemption, and it is what lets a private fund operate without mutual fund style regulation.

  • No more than 100 beneficial owners of the fund's outstanding securities
  • The fund must not make and must not propose to make a public offering, which pairs naturally with Rule 506(b)
  • Because the fund never meets the definition, it never registers as an investment company
Investment Company Act § 3(c)(1); 15 U.S.C. § 80a-3(c)(1)

Two New Jersey tax rules to budget for

The $150 per owner filing fee adds up

A partnership, including a multi member LLC taxed as a partnership, with more than two owners and New Jersey source income or loss pays $150 for each owner, capped at $250,000, with Form NJ-1065 due the 15th day of the fourth month after year end. Half of the next year's fee is prepaid with the return. The investment club exemption will not help a real fund: every owner must be an individual and total assets cannot exceed the lesser of $335,000 or $46,900 per owner (Tax Year 2015 amounts, adjusted annually for inflation). A three member fund LLC with New Jersey source income owes this fee every year (N.J.S.A. 54A:8-6(b)(2)(A); TB-55(R)).

Hedge fund status shields nonresident investors

New Jersey generally requires partnerships to pay tax on behalf of nonresident partners, at 6.37% for noncorporate partners and 9% for corporate partners. The NJ-1065 instructions recognize hedge fund status when the entity's only activity is the purchase, holding, or sale of intangible personal property such as securities, and that property is not held for sale to customers (N.J.S.A. 54A:5-8(c)). With that status, nonresident individual, trust, and estate partners do not report the NJK-1 New Jersey source amount on their nonresident returns, and the partnership makes no nonresident tax payment for them. The entity must evaluate the status each year, and the per owner filing fee is still owed unless all operations and facilities sit outside New Jersey (TB-55(R)).

New Jersey is cheap to form in and strict on advisers

The mechanics are light. $200 forms both LLCs, online filings process in about a business day, the annual report is $75 per entity, and the one securities filing the state requires is a $750 notice through EFD within 15 days of the first New Jersey sale. Total state fees to launch: about $950.

The adviser layer is the real gating question. With no private fund adviser exemption on the books, a New Jersey manager either stays within 5 New Jersey resident clients over any 12 months under N.J.S.A. 49:3-56(g) or registers with the Bureau of Securities, which means $550 a year, a December 31 renewal cycle, and the Series 65 or Series 66 plus Series 7. Whether a private fund counts as a single client for the de minimis is not settled in any primary source, so run that question past counsel before relying on it.

Hedgia forms both LLCs, obtains the EINs, prepares and submits Form D and the New Jersey notice filing at your direction, sets up banking through Axos Bank, and runs investor onboarding, NAV, fees, and K-1 prep. Registration and exemption decisions stay with you and your counsel. Settle the adviser question first: if you cannot stay within 5 New Jersey clients, budget for Bureau registration before the fund takes its first dollar.

New Jersey Bureau of Securities

Common questions

Do I need to register as an investment adviser in New Jersey?

Often yes. New Jersey has no private fund adviser exemption, so the analysis runs through N.J.S.A. 49:3-56. If you have not more than 5 New Jersey resident clients in any 12 consecutive months, the de minimis in 49:3-56(g) exempts you even if you are based in the state. Past that, you register with the Bureau of Securities: $550 per year plus $210 per representative. Federal exempt reporting adviser status does not excuse state registration, and how a private fund is counted as a client is not settled, so confirm with counsel.

What does it cost to start a hedge fund in New Jersey?

State filings total about $950: $100 to form each of the two LLCs (management company and fund) and $750 for the Rule 506 notice filing. Ongoing state costs are $75 per LLC for the annual report, plus the partnership filing fee of $150 per owner once the fund has more than two owners and New Jersey source income or loss. Legal drafting is the traditional expense; the state fees themselves are small.

Does New Jersey require a filing for a Rule 506 offering?

Yes, a notice filing. Rule 506 securities are federally covered, so New Jersey cannot require registration or merit review. It can and does require notice: file Form D through the NASAA Electronic Filing Depository no later than 15 days after the first sale in New Jersey, pay the $750 fee through EFD, and amend within 30 days of any change to the Form D information. This is a notice, not state approval of the offering.

Can I accept non-accredited investors in a New Jersey fund?

Yes, within Rule 506(b) limits: up to 35 non-accredited purchasers per offering, each with the knowledge and experience to evaluate the investment, alongside unlimited accredited investors. General solicitation is off the table under 506(b). Because the securities are federally covered, New Jersey cannot impose its own registration or merit review on the offering; the constraint is federal.

How does New Jersey tax a hedge fund LLC?

A multi member fund LLC is taxed as a partnership, but New Jersey layers on a filing fee: $150 per owner per year, capped at $250,000, once the partnership has more than two owners and New Jersey source income or loss, with half of the next year's fee prepaid. For investors, hedge fund status matters: when the entity only buys, holds, or sells securities not held for sale to customers, nonresident individual, trust, and estate partners do not report the New Jersey source amounts on nonresident returns.

This guide is for educational purposes only and does not constitute legal, financial, or investment advice. Securities laws and regulations change; verify current requirements with the state regulator and qualified counsel before launching any investment fund.

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