Investment Fund Law Blog
Annual Compliance Obligations—What You Need To Know
As the new year is upon us, there are some important annual compliance obligations Investment Advisers either registered with the Securities and Exchange Commission (the “SEC”) or with a particular state (“Investment Adviser”) and Commodity Pool Operators (“CPOs”) or Commodity Trading Advisors (“CTAs”) registered with the Commodity Futures Trading Commission (the “CFTC”) should be aware of.
See upcoming deadlines below and in red throughout this document.
The following is a summary of the primary annual or periodic compliance-related obligations that may apply to Investment Advisers, CPOs and CTAs (collectively, “Managers”). The summary is not intended to be a comprehensive review of an Investment Adviser’s securities, tax, partnership, corporate or other annual requirements, nor an exhaustive list of all of the obligations of an Investment Adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) or applicable state law. Although many of the obligations set forth below apply only to SEC-registered Investment Advisers, state-registered Investment Advisers may be subject to similar and/or additional obligations depending on the state in which they are registered. State-registered Investment Advisers should contact us for additional information regarding their specific obligations under state law.
List of annual compliance deadlines:
| State registered advisers pay IARD fee | November-December (of 2014) |
| Form 13F (for 12/31/14 quarter-end) | February 17, 2015* |
| Form 13H annual filing | February 17, 2015 |
| Schedule 13G annual amendment | February 17, 2015 |
| Registered CTA Form PR (for December 31, 2014 year-end) | February 17, 2015 |
| TIC Form SLT | January 23, 2015 (for December 2014) |
| TIC Form SHCA | March 6, 2015 |
| TIC B Forms | Monthly report (December 2014) – by January 15, 2014Quarterly report (December 31, 2014) – by January 20, 2014 |
| Affirm CPO exemption | March 2, 2015 |
| Registered Large CPO Form CPO-PQR December 31 quarter-end report | March 2, 2015 |
| Registered CPOs filing Form PF in lieu of Form CPO-PQR December 31 quarter-end report | March 31, 2015 |
| Registered Mid-Size and Small CPO Form CPO-PQR year-end report | March 31, 2015 |
| SEC registered advisers and ERAs pay IARD fee | Before submission of Form ADV annual amendment by March 31, 2015 |
| Annual ADV update | March 31, 2015 |
| Delivery of Brochure | April 30, 2015 |
| Delivery of audited financial statements (for December 31, 2014 year-end) | April 30, 2015 |
| California Finance Lender License annual report (for December 31, 2014 year- end) | March 15, 2015 |
| Form PF filers pay IARD fee | Before submission of Form PF |
| Form PF for large liquidity fund advisers (for December 31, 2014 quarter end) | January 15, 2015 |
| Form PF for large hedge fund advisers (for December 31, 2014 quarter end) | March 2, 2015 |
| Form PF for smaller private fund advisers and large private equity fund advisers (for December 31, 2014 fiscal year-end) | April 30, 2015 |
| FBAR Form FinCEN Report 114 (for persons meeting the filing threshold in 2014 and those persons whose filing due date for reporting was previously extended by Notices 2013-1, 2012-2, 2012-1, 2011-2 and 2011-1) | June 30, 2015 |
| FATCA information reports filing for 2014 by participating FFIs | March 31, 2015 |
| Form D annual amendment | One year anniversary from last amendment filing. |
* Reflects an extended due date under Exchange Act Rule 0-3. If the due date of filing falls on a Saturday, Sunday or holiday, a report is considered timely filed if it is filed on the first business day following the due date.