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 due dates for the third 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.
July 10, 2023
Form 13H. Filing is for calendar quarter ended June 30, 2023.
August 14, 2023
Quarterly Form 13F. Filing is for calendar quarter ended June 30, 2023.
Form CTA-PR for Commodity Trading Advisors. Filing is for calendar quarter ended June 30, 2023.
August 29, 2023
Form CPO- PQRfor Commodity Pool Operators. Filing is for calendar quarter ended June 30, 2023.
September 30, 2023
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 such materials. Maintain a list of attendees.[1]
If you have any questions about this Alert, or any other regulatory matters, do not hesitate to reach out to: Daniel Viola (Partner – Head of the Regulatory Group) at 212.573.8038 or via email at dviola@sadis.com or Vartika Naithani at 212.573.8148 or via email at vnaithani@sadis.com.
[1] The Investment Advisers Act of 1940, as amended, does not specify that any training session is necessary and therefore the date on which training should occur is not specified in this Alert. However, a registered investment adviser must distribute and receive signed acknowledgements of changes to its Code of Ethics. Since the Code of Ethics (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 the adviser’s personnel up-to-date with regard to policies and procedures and should otherwise remind personnel of their ongoing compliance obligations.
