Compliance Deadlines - Second 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 second quarter of 2016. Please note that this is general advice that is applicable to most investment advisers with a December 31st fiscal year end. This list is not exhaustive and contains some best practice compliance suggestions. April 15, 2016 Brokerage Committee Meeting. Conduct quarterly brokerage committee meeting.
April 30, 2016 Private Fund Audited Financial Statements. Distribute audited financial statements to investors for any private investment fund for which the adviser or a related person has custody of the fund's assets, assuming the adviser is registered with the U.S. Securities and Exchange Commission ("SEC") or a state authority.
Access Person Quarterly Transaction Reports. Collect quarterly reports from access persons for their personal securities transactions.
Code of Ethics and Compliance Manual. Distribute code of ethics and compliance manual to employees, including acknowledgment form.
Annual Delivery of Form ADV Part 2. Send to all clients and fund investors a copy of the adviser's Form ADV Part 2, assuming the adviser is registered with the SEC or a state authority. 
Annual Filers - Form PF with SEC. Private equity funds and smaller private fund advisers with a December 31st calendar year end, assuming the adviser is registered with the SEC.
May 15, 2016 Form 13F. File any required Form 13F with the SEC.
June 15, 2016 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.
June 30, 2016 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.
If you have any questions about this Alert, please contact Daniel G. Viola at 212.573.8038 or email@example.com.