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Request Supervised Persons Complete Annual Attestations

As compliance best practice and/or possibly a requirement under an investment adviser firm's compliance manual, each supervised person of the firm should submit the following items to the firm's chief compliance officer ("CCO") or designee on an annual basis: Each supervised person should confirm in writing that such individual has re-reviewed and understands the firm's […]

Request/Verify Each Access Person’s Annual Holdings Report of Personal Securities

In general, an investment adviser firm's code of ethics requires each access person within the firm to submit annually to the firm's chief compliance officer ("CCO") or other designee a report of the access person's current personal securities holdings. Typically, the report must include the following information: The title and type of security, and as […]

Form 13H Annual Filing Deadline

Under Section 13(h) of the Securities Exchange Act, Form 13H must be filed by any organization that is considered a large trader. An investment adviser firm qualifies as a “large trader” when the firm has discretionary authority over one or more accounts that purchase or sell any exchange-listed security in an aggregate amount equal to […]

Request Supervised Persons Complete Annual Attestations

As compliance best practice and/or possibly a requirement under an investment adviser firm's compliance manual, each supervised person of the firm should submit the following items to the firm's chief compliance officer ("CCO") or designee on an annual basis: Each supervised person should confirm in writing that such individual has re-reviewed and understands the firm's […]

Request/Verify Each Access Person’s Annual Holdings Report of Personal Securities

In general, an investment adviser firm's code of ethics requires each access person within the firm to submit annually to the firm's chief compliance officer ("CCO") or other designee a report of the access person's current personal securities holdings. Typically, the report must include the following information: The title and type of security, and as […]

Form 13H Annual Filing Deadline

Under Section 13(h) of the Securities Exchange Act, Form 13H must be filed by any organization that is considered a large trader. An investment adviser firm qualifies as a “large trader” when the firm has discretionary authority over one or more accounts that purchase or sell any exchange-listed security in an aggregate amount equal to […]

Request Supervised Persons Complete Annual Attestations

As compliance best practice and/or possibly a requirement under an investment adviser firm's compliance manual, each supervised person of the firm should submit the following items to the firm's chief compliance officer ("CCO") or designee on an annual basis: Each supervised person should confirm in writing that such individual has re-reviewed and understands the firm's […]