Compliance Dates - 4th Quarter 2014

Compliance Deadlines There are many regulatory filings and compliance forms that investment managers need to complete throughout the year. Below is a list of some of the key compliance dates for the remainder of 2014. Please note that this is general advice that is applicable to most investment managers with a December 31st fiscal year end. In addition, please note that registered investment advisers that have less than $1.5 billion of regulatory assets under management would generally only file the Form PF on an annual basis, not a quarterly basis as set forth below. Likewise, the Form 13F deadline generally only applies if an investment manager has discretion over $100 million or more in 13(f) securities.

Investment managers must consider the following key compliance tasks and dates:

September 30, 2014

Form 13H. Review transactions and assess whether Form 13H needs to be amended.

Form PF. Review assets/holdings to determine filing requirements.

Pooled Quarterly Report (PQR) (For Registered Commodity Pool Operators). Quarterly financial reports to be filed using NFA Easy File System.

October 30, 2014

Access Person Quarterly Transaction Reports. Collect quarterly reports from access persons for their personal securities transactions

November 10, 2014 – December 12

State Notice Filings and Fees. Submit any required notice filings with all appropriate states, which typically are made through the IARD system, and pay an annual fee.

November 14, 2014

Form 13F. File any required Form 13F with the SEC.

November 30, 2014[1]

Quarterly Employee Compliance Training. Conduct a quarterly employee training session to review requirements under the adviser's written compliance policies and procedures, including the code of ethics, as well as any material changes to these materials. Maintain list of attendance.

December 31, 2014

Form 13H. Review transactions and assess whether Form 13H needs to be amended.

Form PF. Review assets/holdings to determine filing requirements.

Pooled Quarterly Report (PQR)(For Registered Commodity Pool Operators). Quarterly financial reports to be filed using NFA Easy File System.

Form 40. Every trader who holds or controls a reportable futures and option position must file Form 40 with the CFTC by the deadline specified by the CFTC. If Form 40 is required, certain additional books and records requirements apply.

[1] The Advisers Act does not specify that any training session is necessary, and therefore the date on which training should occur is not specified. However, a registered adviser must distribute and receive signed acknowledgements of changes to its code of ethics. Since the code (as well as an adviser's compliance policies and procedures) may be amended as part of an adviser's annual review, as well as at any other time, quarterly training should help to keep personnel up to date regarding policies and procedures and otherwise remind personnel of their compliance obligations.

 

Cheryl Spratt