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 third 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.
July 11, 2022
Form 13H. Filing is for calendar quarter ended June 30, 2022.
August 15, 2022
Quarterly Form 13F. Filing is for calendar quarter ended June 30, 2022.
Form CTA-PR for Commodity Trading Advisors.
September 30, 2022
Pooled Quarterly Report (PQR) For Commodity Pool Operators.
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 attendees.*
If you have any questions about this Alert, please contact Daniel G. Viola at 212.573.8038, dviola@sadis.com or Nicole Arrow at 212.573.8148, narrow@sadis.com.
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* The Investment Advisers Act of 1940 does not specify that any training session is necessary, and therefore the date on 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.
