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 2022. 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 11, 2022
Form 13H. Filing is for calendar quarter ended March 31, 2022.
April 30, 2022
Code of Ethics and Compliance Manual. Distribute code of ethics and compliance manual to employees, including acknowledgement form.
Annual Delivery of Form ADV Part 2. Send clients a copy of the adviser’s Form ADV Part 2A or a summary of material changes.[1]
Form PF with SEC. This filing applies to private funds that manage more than $150 million.
May 16, 2022
Quarterly Form 13F. Filing is for calendar quarter ended March 31, 2022.
Form CTA-PR for Commodity Trading Advisors.
May 30, 2022
Pooled Quarterly Report (PQR) For Commodity Pool Operators.
June 30, 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 attendees.[2]
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
Nicole Arrow (Associate) at 212.573.8148 or via email at narrow@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.
