"[A16Z] are registering their entire firm—all 150 people—as financial advisors... [So] If the firm wants to put $1 billion into cryptocurrency or tokens, or buy unlimited shares in public companies or from other investors, it can."

A distinction of VC vs investment advisory at the associate level, is the direction of persuasion. Outside of partners, the bulk of VC associates go around visiting/researching startups, looking to buy *in*. Doesn't matter if the aim is to restructure, reorganize, lbo, make fundamental improvements, take them public, or whatever, usually it's the VC who's getting sold to.

An investment advisor goes around raising capital to be invested with discretionary authority, in exchange for some contractual fee, generally a small annual fee. At the lowest associate level, it's equivalent to a series 65 licensed or maybe a CFA *salesperson,* the opposite from the above situation; it'll be the advisor doing the selling, selling his ability to generate returns for the prospective client.

Horowitz talks about "going deeper into riskier bets" but this change only lets the VC firm risk new "other people's money" rather than its own general portfolio funds. If it wanted to invest in some crypto startup in its previous form, it already could, without any need for federal oversight...many levels it can already get in, seed, series A, series B, simply buy the ICO, underwrite debt instruments for the coin startup and buy the bonds etc.

It's likely the VC firm is exploiting front running circumvention, ie going long on some position using its general fund, in anticipation and hopes of putting new OPM into the same positions, wouldn't be surprised tbh that shit goes on all the time. There's also no guarantee those 150 VC associates can even bring in new OPM.

/r/ethtrader Thread Link - forbes.com