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 2023. 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 10, 2023
April 30, 2023
May 15, 2023
May 30, 2023
June 30, 2023
If you have any questions about this Alert, please contact Daniel G. Viola at 212.573.8038, dviola@sadis.com or Vartika Naithani at 212.573.8148, vnaithani@sadis.com
[1] An adviser is required to deliver Form ADV Part 2 to clients; it is not required to deliver Form ADV Part 2 to investors in a pooled investment vehicle. However, it is considered a best practice and is recommended that an adviser delivers Form ADV Part 2 to each investor in a pooled investment vehicle.
[2] The Investment Advisers Act of 1940 does not specify that any training session is necessary and therefore the date of 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.