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 fourth quarter of 2022. Please note that this is a 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.
October 11, 2022
· Quarterly Form 13H. File this if you had changes to your Form 13H in the 3rd quarter of 2022.
November 14, 2022
· Quarterly Form 13F. File this if you are an Institutional Investment Manager, managing securities, having an aggregate fair market value of at least $100,000,000. Should include information for third quarter of 2022.
· Form CTA- PR. File with National Futures Association for 3rd quarter of 2022.
November 29, 2022
· Form CPO-PQR. File with the National Futures Association for 3rd quarter of 2022.
December 31, 2022
· 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 a list of all attendees.[1]
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] The Investment Advisers Act of 1940 does not specify that any training 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.
