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Deadline for Payment under Final Renewal Statement

If an investment adviser firm owes additional fees on the Final Renewal Statement, the investment adviser firm must pay by the Final Renewal Statement’s due date (January 27, 2023). General Disclosure: The information contained in this sample calendar event is general in nature intended for educational purposes only and is not intended to be a […]

Determining Whether Required to File Form 13F

An institutional investment manager, which includes an investment adviser firm, ("Manager") must use Form 13F for reports to the SEC required by Section 13(f) of the Securities Exchange Act of 1934 (“Exchange Act”). Rule 13F-1 provides that every Manager which exercises investment discretion with respect to accounts holding Section 13(f) securities having an aggregate fair […]

Form 13F Filing Deadline for 4Q 2022

To the extent an investment adviser firm is required to file the Form 13F, the quarterly report for 4th calendar quarter of 2022 is due Tuesday, February 14, 2023. Rule 13f-1(a)(1) under  the Securities Exchange Act requires an investment adviser to submit four Form 13F filings if it had discretion of $100 million or more […]

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 […]

Submission of Annual Financial Statements in Certain States

As a state registered investment adviser firm completes its Form ADV Annual Amendment, it’s important not to forget that many state securities regulators also require a state registered investment adviser firm to submit annual financial statements and/or other documents (e.g., proof of continued coverage of a surety bond, investment advisory client agreement if material changes) […]

Delivery of Form ADV Part 2A to Existing Clients

An investment adviser is required to deliver to each client, annually within 120 days after the end of the investment adviser’s fiscal year and without charge, if there are material changes to the investment adviser’s brochure since the investment adviser’s last annual updating amendment: (1) a current copy of the investment adviser’s disclosure brochure (Form […]

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 […]