For a long time managers of many funds were not required to register as investment advisers. This is changing and fund managers (or would-be fund managers) now have a number of important requirements to meet. The changes affect funds that invest in other funds or that purchase securities – which may well include promissory notes (even those secured by deeds of trust). The impact can be especially great on fund managers with funds of fewer than 100 investors. If you’re such a fund manager, grab a cup of coffee (or better yet, a glass of wine) and bear with me.