Investment Fund Law Blog
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. 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 in chronological order:
| State registered advisers pay IARD fee | November-December (of 2013) |
| Form 13F (for 12/31/13 quarter-end) | February 14, 2014 |
| Form 13H annual filing | February 14, 2014 |
| Schedule 13G annual amendment | February 14, 2014 |
| Registered CTA Form PR (for December 31, 2012 year-end) | February 14, 2014 |
| TIC Form SLT | Every 23rdcalendar day of the month following the report as-of date |
| TIC Form SHCA | March 3, 2014 |
| Affirm CPO exemption | March 3, 2014 |
| Registered Large CPO Form CPO-PQR December 31 quarter-end report | March 3, 2014 |
| Registered CPOs filing Form PF in lieu of Form CPO-PQR December 31 quarter-end report | March 31, 2014 |
| Registered Mid-Size and Small CPO Form CPO-PQR year-end report | March 31, 2014 |
| SEC registered advisers and ERAs pay IARD fee | Before submission of Form ADV annual amendment by March 31, 2014 |
| Annual ADV update | March 31, 2014 |
| Delivery of Brochure | April 30, 2014 |
| Form PF filers pay IARD fee | Before submission of Form PF |
| Form PF (for advisers required to file within 120 days after December 31, 2013 fiscal year-end) | April 30, 2014 |
| FBAR Form TD F 90-22.1 (for persons meeting the filing threshold in 2013) | June 30, 2014 |
| FATCA registration | Must be completed by April 25, 2014 |
| Form D annual amendment | One year anniversary from last amendment filingIf the fund will be using 506(c) to generally solicit, the Form D must be amended to check the box that indicates the offering will be made under 506(c) |