Compliance Deadlines First Quarter 2016
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 first quarter of 2016. Please note that this is general advice that is applicable to most investment managers with a December 31st fiscal year end. This list is not exhaustive and contains some best practice compliance suggestions. January 15, 2016 Form PF. Large Liquidity Fund Advisers must file for the quarter ending December 31, 2015.
January 16, 2016 IARD Filing Fees. Ensure that the IARD account is properly funded to facilitate filing the annual adviser registration renewal Form ADV.
January 30, 2016 Access Person Annual Holdings Reports. Collect annual holdings reports from access persons for their personal securities holdings.
February 15, 2016 Annual Amendment to Form 13H. Due 45 days after calendar year end. Any subsequent updates due within 10 days after each quarter-end. Schedule 13G. File any required Schedule 13G with the SEC and the issuer. Form 13F. File any required Form 13F with the SEC. Form 13H. File annual update with the SEC. Form 5. File any required Forms 5 with the SEC, the issuer and the appropriate exchange.
February 29, 2016 Form PF. Large Hedge Fund Advisers must file for the quarter ending December 31, 2015. NFA/CFTC - 2016 Annual Exemption Affirmation due. March 10, 2016 Form N-CSR. Registered Investment Companies (e.g., mutual funds, exchange traded funds) must file their certified shareholder annual report with the SEC.
March 30, 2016 Form ADV Part 1, Part 2. Amend Form ADV Part 1 and Part 2, file the amended document with the SEC through the IARD system. Anniversary Date of Filing Annual Form D. Amendment due on or before anniversary date of prior Form D filers. CPO/CTA Questionnaires. Due on or before anniversary date, and promptly when material information changes.
If you have any questions about this Alert, please contact Daniel G. Viola at 212.573.8038 or firstname.lastname@example.org.
 Although Rule 204A-1 does not specify the exact date when annual holdings reports must be submitted by access persons, January 30 seems to be an appropriate time to collect annual holdings reports. Fourth quarter brokerage statements, which generally should be deemed to satisfy this requirement (along with a separate report of any securities which do not appear on the brokerage statements), will be current as of 45 days prior to the date of submission, in accordance with the rule.  When a Schedule 13G, Form F or Form 5 filing deadline falls on a weekend or federal legal holiday, a person may file a required report on the next business day. See Exchange Act Rule 0-3(a).  If the 90-day deadline for filing the annual Form ADV updating amendment falls on a weekend or a holiday, an adviser's filing deadline is not extended by one business day. Rather the adviser must file its amendment on the last business day preceding the 90-day deadline.