How is the Nittany Lion Fund allowed to have non-licensed Fund Managers?

I am in the process of starting my own Quantitative Hedge Fund in the State of Pennsylvania. I currently don't have any FINRA licenses and was researching firms that have been able to start without licensed Fund Managers.


I came across the Nittany Lion Fund, a student run Hedge Fund at Penn State University with 15MM under management. I am wondering how the Nittany Lion Fund is legally able to manage investor capital with student fund managers?


Are they using some sort of SEC Exemption Laws? Am I able to utilize the same thing for my own Hedge Fund that I am starting?

 

It's most likely an investment club which is explicitly exempted from registration under the securities act: https://www.sec.gov/about/reports-publications/investor-publications/in…

Here's how you can legally run an exempt investment club:

1. don't charge any fees of any kind for managing the investments

2. have fewer than 100 members

3. require that every member of the club have an active interest in trading for the fund. no passive investors are permitted.

 

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