2016 Investment Adviser Compliance Calendar

2016 Investment Adviser Compliance Calendar

25602 Alicia Parkway #107 Laguna Hills, CA 92653 Main (800) 641-1818 Tel (949) 770-6154 Fax (949) 770-6198 www.financialregistrations.com

http://www.financialregistrations.com/



2016 Client Advisory Series No. 17- Investment Adviser Compliance Calendar Page 1 of 16 © 2016 Financial Registrations, Inc. IACC. Ver. 02092016

Forward

Dear Reader,

Our 2016 Investment Adviser Compliance Calendar update is intended to keep investment advisers informed of updated compliance reporting requirements and filing deadlines as well as provide information on market holidays and events that may affect investment adviser business operations.

This information is divided into two categories: compliance reporting and filing deadlines that are established on a calendar year basis and event-driven requirements that are set internally by investment advisory firms based on their previous year’s completion dates.

While this information is intended to be used as a reference guide when preparing and planning your annual investment adviser compliance program, we encourage each investment adviser firm to review its specific needs to determine the applicability of such requirements.

Although this information is primarily focused on SEC registered investment advisers, as federal and/or state investment adviser rules and regulations are subject to change, information on specific requirements as provided in this calendar should be verified to ensure compliance with current regulatory reporting requirements.

Sincerely,

Scott P. Tarra Managing Principal




Contents

Quick Guide……………………………………………………………..

Event-Driven Requirements……………………………..……….....

Date-Driven Requirements…………………….…………….….......

January………………………………………………………….......

February……………………………………………………….........

March ………………………………………………………...…......

April…………………………………………………………….........

May……………………………………………………………..........

03

04

05

05

05

06

06

08

June…………………………………………………………........................

July………………………………………………………............................

August ………………………………………………………...…................

September……………………………………………………………...........

October……………………………………………………………...............

November……………………………………………………………………..

December……………………………………………………………………..

January 2017………………………………………...……………………….

09

09

11

11

11

13

13

14




Quick Guide

JANUARY M T W T F S S 1 2 3

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

FEBRUARY M T W T F S S 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29

MARCH M T W T F S S 1 2 3 4 5 6

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

APRIL M T W T F S S 1 2 3

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

MAY M T W T F S S 1

2 3 4 5 6 7 8 9 10 11 12 13 14 15

16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

JUNE M T W T F S S 1 2 3 4 5

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

JULY M T W T F S S 1 2 3 4 5 6 7 8 9 10

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

AUGUST M T W T F S S 1 2 3 4 5 6 7 8 9 10 11 12 13 14

15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

SEPTEMBER M T W T F S S 1 2 3 4

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

OCTOBER M T W T F S S 1 2

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

NOVEMBER M T W T F S S 1 2 3 4 5 6

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

DECEMBER M T W T F S S 1 2 3 4

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

[ ]= Compliance Requirements/Due Date [ ]= Market Holiday/Market Close




Update: February 9, 2016 By Scott P. Tarra Managing Principal [email protected]

Due Date Completed N/A Compliance Requirement Category Frequency Assignment Description/Rule Ref.

Event-Driven Requirements (based on previous year's completion dates)

TBD Annual Compliance Review Internal Controls Annually CCO

Rule 206(4)-7 -- Compliance Procedures and Practices- Registered investment advisers must conduct an annual compliance review regarding the adequacy of its policies and procedures and the effectiveness of their implementation; generally conducted on a 12 month rolling basis.

TBD Annual Personal Securities Holdings Report Internal Controls Annually CCO

Rule 204A-1 -- Investment Adviser Code of Ethics- Investment advisers are reminded to annually collect from each "Access Person" an annual personal securities holding report containing information required securities holdings and securities accounts.

TBD Annual Compliance Training Training & Education Annually CCO

Rule 206(4)-7 -- Compliance Procedures and Practices- Although not specifically required under the Investment Advisers Act of 1940, investment advisers are encouraged to conduct training for all access persons and employees as part of an effective compliance program.

TBD Completion of Annual Compliance Certifications- all Access Persons Internal Controls Annually CCO

Rule 206(4)-7 -- Compliance Procedures and Practices; Rule 204A-1 -- Investment Adviser Code of Ethics- All access persons should be asked to reaffirm their understanding and awareness of the compliance manual and code of ethics in conjunction with annual compliance training.

TBD

Annual Review and Update of Core Compliance Forms & Documents (e.g. Compliance Procedures; Cybersecurity Procedures; Code of Ethics; Privacy Policy; Business Continuity Plan, etc.) Internal Controls Annually CCO/C

Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are reminded that reviews of core compliance forms & documents should be undertaken on a periodic basis. Registered investment advisers may undertake this review as part of their annual compliance review (or more frequently if material changes/updates occur).

TBD Form D Annual Amendment Filing(s) Regulatory Reporting Annually CCO

Form D filings for funds with ongoing offerings of securities in reliance on Rule 506 of Regulation D are reminded that an amendment to Form D is required to be filed with the SEC annually at a minimum, on or before the anniversary of the initial Form D filing. Certain changes throughout the year also may trigger a Form D amendment obligation (common for hedge funds and increasingly common for private equity funds)


mailto:[email protected]



Due Date Completed N/A Compliance Task Category Frequency Assignment Rule Reference/Description

Date-Driven Requirements (based on calendar year due dates) 01/01/16 New Year's Day Market Holiday Annually

01/04/16 2016 Final Renewal Statement Availability Renewals Annually CFO FINRA Renewal Program Calendar -- Investment advisers must confirm full payment of their renewal fees as reflected on their Final Renewal Statement.

01/18/16 Martin Luther King Jr. Day Market Holiday Annually

01/27/16 Monthly Financials (as of Dec. 31, 2015) Financial Statements Monthly CFO

Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

02/11/16 Annual Entitlement User Accounts Certification Process (for Super Account Administrator or SAA)

Regulatory Reporting Annually CCO

FINRA Annual Entitlement User Accounts Certification Process -- Certification process must be completed by the designated SAA through IARD system.

02/14/16 Form 13F Filing (First Time Filers; Q4 2015) Regulatory Reporting Quarterly CCO

Section 13(f) of the Securities Exchange Act of 1934 -- Registered investment advisers must file a Form 13F if they exercise investment discretion with respect to $100 million or more in certain identified 13F securities within 45 days after the end of the year in which the adviser reaches the $100 million filing threshold. The measurement date for calculating $100 million threshold is as of the last calendar day of any month in a given year. Thereafter, advisers must make 13F filings within 45 days after end of calendar quarter.

02/14/16 Form 13H Filing (First Time Filers; Q4 2015) Regulatory Reporting Quarterly CCO

Rule 13h-1(a)(1) -- Large Trader Reporting- Registered investment advisers meeting the SEC's "large trader" thresholds (i.e. trades (i) 2 million shares or $20 million FMV daily or (ii) 20 million shares or $200 million FMV monthly) are required to file an initial Form 13H with the SEC within 10 days of triggering the threshold. Large traders also need to amend Form 13H annually within 45 days of year-end and make quarterly update filings to the extent that information changes.

02/14/16 Schedule 13G/D and Section 16 Filings Regulatory Reporting Annually CCO

Exchange Act Sections 13(d) and 13(g) and Regulation 13D-G -- Investment advisers who exercise investment discretion over funds that are beneficial owners of 5% or more of a registered voting equity security must report these positions on Schedule 13G or Schedule 13D. Note: Schedule 13G filings must be updated annually within 45 days of the end of the year. Schedule 13D filings need to be amended when any material change (including a change of 1% or more of the securities reported as beneficially owned) in the prior Schedule 13D has occurred. Any necessary Section 16 filings (Form 3, 4 or 5) also should be reviewed.

02/15/16 Presidents' Day Market Holiday Annually





02/24/16 Monthly Financials (as of Jan. 31, 2016) Financial Statements Monthly CFO


02/29/16 Commodity Pool Operator (CPO) Exemption Regulatory Reporting Annually CCO

CFTC Regulation 4.13(a)(3) -- Investment advisers relying on the exemption from registration with the U.S. Commodity Futures Trading Commission (CFTC) pursuant to the "de minimis exemption" of CFTC Regulation 4.13(a)(3), must reaffirm their claim of exemption with the National Futures Association (NFA) each year annually within 60 days of the end of the calendar year.

03/23/16 Monthly Financials (as of Feb. 29, 2016) Financial Statements Monthly CFO


03/31/16 Form ADV Part 1 & 2A/B Annual Update (FYE Dec. 31, 2015)


Rule 204-1 -- Amendments to Application for Registration- Registered investment advisers and exempt reporting advisers (ERAs) must file an annual amendment to Form ADV with the SEC and/or state securities authorities within 90 days of their fiscal year end. Note that any material change to an adviser's business throughout the course of the year requires amending the Form ADV promptly after the change.

03/31/16 Special Note on California Private Fund Adviser Exemption


California Code of Regulations, Rule 260.204.9 -- California advisers that are eligible for exemption from adviser registration with the California Department of Business Oversight (DBO) must file Part 1 of the Adviser's Form ADV with the DOC within 90 days of fiscal year end.

03/25/16 Good Friday Market Holiday Annually

04/15/16 Quarterly Compliance Review & Recap (Q1 2016) Internal Controls Quarterly CCO

Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a monthly compliance review and recap of select areas of their advisory business within 15 days after the end of each month.

04/15/16 Sample Review of New Advisory Accounts/Agreements/Documentation

Customer Accounts Quarterly CCO

Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers); Rule 204-3 (Written Disclosure Statements)

04/15/16 Sample Review of OFAC Checks & Customer Identity on New Accounts AML Quarterly CCO

*Best Practice -- see Bank Secrecy Act of 1970, Money Laundering Control Act of 1986 or USA PATRIOT Act

04/15/16 Sample Review of Advisory Transactions Trading & Trans. Quarterly CCO Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers

04/15/16 Review of Newly Hired/Terminated IA Reps Advisory Personnel Quarterly CCO

Ref. Rule 206(4)-4 -- Financial and Disciplinary Information that Investment Advisers Must Disclose to Clients

04/15/16 Review of Customer Complaints Internal Controls Quarterly CCO Rule 204-2(a)(7) -- Books and Records to Be Maintained by Investment Advisers




Due Date Completed N/A Compliance Task Category Frequency Assignment Rule Reference/Description 04/15/16 Sample Review of Gifts & Gratuities Internal Controls Quarterly CCO Rule 204A-1 -- Investment Adviser Code of Ethics

04/15/16 Sample Review of Activity/Exception Reports Trading & Trans. Quarterly CCO Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers

04/15/16 Sample Review of Written/Electronic Business Related Correspondence Communications Quarterly CCO

Rule 204-2(a)(7) & (11) & 204-2(g) -- Books and Records to Be Maintained by Investment Advisers

04/15/16 Sample Review of Advertising Materials Communications Quarterly CCO Rule 206(4)-1 -- Advertisements by Investment Advisers

04/15/16 Sample Review of Social Media by Firm/Access Persons Communications Quarterly CCO SEC IM Guidance on the Testimonial Rule and Social Media (March 2014; No. 2014-04)

04/15/16 Sample Review of Personal Securities Transactions & Qtrly Reports Internal Controls Quarterly CCO Rule 204A-1 -- Investment Adviser Code of Ethics (Quarterly Transaction Reports)

04/15/16 Sample Review of Outside Business Activities Internal Controls Quarterly CCO Rule 204A-1 -- Investment Adviser Code of Ethics; Form U4 Instructions

04/15/16 Review and Update Restricted Securities & Watch List Internal Controls Quarterly CCO Rule 204A-1 -- Investment Adviser Code of Ethics

04/15/16 Review Compliance & Cybersecurity Procedures for Material Updates Internal Controls Quarterly CCO

Rule 206(4)-7 -- Compliance Procedures and Practices; SEC OCIE 2015 Cybersecurity Examination Initiative (Volume IV, Issue 8; September 15, 2015)

04/15/16 Review Business Continuity/Disaster Recovery Plan for Material Updates Internal Controls Quarterly CCO

Rule 206(4)-7 -- Compliance Procedures and Practices; also see Joint Review of Business Continuity and Disaster Recovery of Firms conducted by the SEC, CFTC and FINRA (Aug. 16, 2013)

04/15/16 Review Code of Ethics for Material Updates Internal Controls Quarterly CCO Rule 204A-1 -- Investment Adviser Code of Ethics

04/15/16 Review Privacy Policy for Material Updates Internal Controls Quarterly CCO Reg. S-P -- Privacy of Consumer Financial Information

04/15/16 Review Firm Agreements (e.g. Sub-Adviser, Solicitation, Vendor, etc.) Internal Controls Quarterly CCO Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers

04/15/16 Form PF Filing-- Large liquidity fund advisers (Q1 2016) Regulatory Reporting Quarterly CCO

Rule 204(b)-1 -- Reporting by investment advisers to private funds; Rule 2a-7 -- Money Market Funds- Liquidity fund advisers with at least $1 billion in combined assets under management attributable to liquidity funds and registered money market funds must file Form PF to update information regarding the liquidity funds they manage within 15 days of the end of each fiscal quarter.

04/25/16 Monthly Financials (as of Mar. 31, 2016) Financial Statements Monthly CFO


04/29/16

Delivery of Updated Form ADV Part 2A (Brochure) and Form ADV Part 2B (Brochure Supplement) to advisory clients Client Disclosures Annually CCO

Rue 204-3(b)(2) -- Delivery of brochures and brochure supplements- Investment Advisers must deliver to each client, annually within 120 days after the end of your fiscal year and without charge, if there are material changes in your brochure since your last annual updating amendment.





04/29/16 Annual Privacy Policy Notice Client Disclosures Annually CCO

SEC Regulation S-P -- Privacy of Consumer Financial Information- Current privacy policies should be disclosed to advisory clients who are natural persons on an annual basis; this is generally completed concurrently with the delivery of the Form ADV Part 2A (Brochure) and Form ADV Part 2B (Brochure Supplement).

04/29/16 Mailing of Annual Disclosure Documents to Clients (BCP Statement, etc.) Client Disclosures Annually CCO

Additional disclosure documents should be provided to advisory clients who are natural persons on an annual basis; this is generally completed concurrently with the delivery of the Form ADV Part 2A (Brochure) and Form ADV Part 2B (Brochure Supplement)

04/29/16 Form PF Filing--Small private fund advisers (FYE December 31, 2015)


Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers that have at least $150 million in private fund assets under management but do not exceed a “large adviser” threshold must file Form PF only once a year, within 120 days of the end of the fiscal year.

04/29/16 Form PF Filing-- Large private equity advisers (FYE December 31, 2015)

Regulatory Reporting Quarterly CCO

Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers with at least $2 billion in assets under management attributable to private equity funds must file Form PF annually within 120 days of the end of the fiscal year.

04/29/16 Delivery of Audited Financial Statements (FYE December 31, 2015)

Financial Reporting Annually CFO

Rule 206(4)-2(b)(4)(i) -- Custody or Possession of Funds or Securities of Clients by Investment Advisors- Registered investment advisers relying on the “audited financials exception” to the account statement delivery and independent verification requirements of the Custody Rule must deliver such audited financial statements for their fund to investors within 120 days of the end of the fund’s fiscal year.

04/29/16 Custody Rule Annual Audit (FYE December 31, 2015)

Financial Reporting Annually CFO

Rule 206(4)-2(a)(4)(i) -- Custody or Possession of Funds or Securities of Clients by Investment Advisors- Registered investment advisers must comply with certain custody procedures by having an independent public accountant registered with the Public Company Accounting Oversight Board prepare audited financial statements in accordance with GAAP and sending such audited financial statements to investors within 120 days after the fund’s fiscal year-end.

05/15/16 Form 13F Filing (Q1 2016) Regulatory Reporting Quarterly CCO






05/15/16 Form 13H Filing (Q1 2016) Regulatory Reporting Quarterly CCO


05/24/16 Monthly Financials (as of Apr. 30, 2016) Financial Statements Monthly CFO


05/27/16 Friday before Memorial Day (3 p.m. early close) Market Holiday Annually

05/30/16 Memorial Day Market Holiday Annually

05/31/16 Form PF Filing-- Large hedge fund advisers (Q1 2016) Regulatory Reporting Quarterly CCO

Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers with at least $1.5 billion in assets under management attributable to hedge funds must file Form PF to update information regarding the hedge funds they manage within 60 days of the end of each fiscal quarter.

06/23/16 Monthly Financials (as of May 31, 2016) Financial Statements Monthly CFO


07/01/16 Day before Independence Day (1 p.m. early close) Market Holiday Annually

07/04/16 Independence Day (observed) Market Holiday Annually















Due Date Completed N/A Compliance Task Category Frequency Assignment Rule Reference/Description 07/15/16 Sample Review of Gifts & Gratuities Internal Controls Quarterly CCO Rule 204A-1 -- Investment Adviser Code of Ethics


















07/26/16 Monthly Financials (as of Jun. 30, 2016) Financial Statements Monthly CFO










08/23/16 Monthly Financials (as of Jul. 31, 2016) Financial Statements Monthly CFO




09/02/16 Friday before Labor Day (3 p.m. early close) Market Holiday Annually

09/05/16 Labor Day Market Holiday Annually

09/26/16 Monthly Financials (as of Aug. 31, 2016) Financial Statements Monthly CFO


10/10/16 Columbus Day Market Holiday Annually
















10/15/16 Sample Review of Gifts & Gratuities Internal Controls Quarterly CCO Rule 204A-1 -- Investment Adviser Code of Ethics






















10/25/16 Monthly Financials (as of Sept. 30, 2016) Financial Statements Monthly CFO


11/11/16 Veterans Day Market Holiday Annually





11/23/16 Monthly Financials (as of Oct. 31, 2016) Financial Statements Monthly CFO


11/23/16 Day before Thanksgiving Day (3 p.m. early close) Market Holiday Annually

11/24/16 Thanksgiving Day Market Holiday Annually

11/25/16 Day after Thanksgiving Day (1 p.m. early close) Market Holiday Annually



12/23/16 Monthly Financials (as of Nov. 30, 2016) Financial Statements Monthly CFO





Due Date Completed N/A Compliance Task Category Frequency Assignment Rule Reference/Description 12/26/16 Christmas Day (Observed) Market Holiday Annually

12/26/16 Last Day to submit 2017 Preliminary Renewal Filing and Payment prior to year-end Renewals Annually CFO FINRA Annual Renewal Program Calendar

12/28/16 Web CRD/IARD are unavailable due to Final Renewal Statement and renewals processing Renewals Annually CFO FINRA Annual Renewal Program Calendar

12/30/16 Web CRD/IARD are available for QUERY-only and the creation of "Pending" 2017 Renewal filings Renewals Annually CFO FINRA Annual Renewal Program Calendar

12/31/16 Year-End Compliance Review Checklist Internal Controls Annually CCO

Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a year-end compliance review checklist to ensure that all applicable compliance requirements were completed for the current year.












01/15/17 Sample Review of Gifts & Gratuities Internal Controls Quarterly CCO Rule 204A-1 -- Investment Adviser Code of Ethics






















01/26/17 Monthly Financials (as of Dec. 31, 2016) Financial Statements Monthly CFO











About Us

Financial Registrations, Inc. is a compliance management consulting firm providing registration, enterprise compliance and risk management solutions to the financial services industry. We specialize in providing customized compliance solutions to FINRA member broker/dealers and SEC and State registered investment advisers. With former securities regulators and industry professionals on staff, we offer a full array of talent and experience necessary for handling the most recent and complex compliance issues facing the financial services industry.

For more information on this topic or other compliance related matters, please contact:

Scott P. Tarra Brian K. Miller Managing Principal VP Business Development [email protected] [email protected] Financial Registrations, Inc. Toll-free (800) 641-1818 25602 Alicia Parkway #107 Direct (949) 770-6154 Laguna Hills, CA 92653 Fax (949) 770-6198 www.financialregistrations.com

Recent Publications

2016 Broker/Dealer Compliance Calendar 2016 State Requirements for Broker/Dealer Annual Audited Financial Statements

Investment Adviser State De Minimis Exemptions





http://issuu.com/scotttarra/docs/fr_2016_bd_compliance_calendar_0128?e=16312604/33095485

http://issuu.com/scotttarra/docs/fr_ca_no._15-_srbdaafs_final?e=16312604/33134729

http://issuu.com/scotttarra/docs/fr_client_advisory_no._26-_ia_state?e=16312604/15350529

2016 Investment Adviser Compliance Calendar

Documents

Transcript of 2016 Investment Adviser Compliance Calendar