Compliance Reminders for 2021
Registered investment advisers are required to make filings with the Securities and Exchange Commission (SEC) each year and deliver certain information to their clients. In particular, registered investment advisers must:
- File their annual amendment to Form ADV by March 31, 2021.
- Deliver their brochure (or Form ADV Part 2) to their clients by April 30, 2021.
- If using client audited financial statements to comply with the custody rule, deliver such financial statements to clients by April 30, 2021.
- File Form PF either on April 30, 2021, or, if the investment adviser is "large hedge fund adviser", 60 days after the end of each quarter.1
- Deliver their privacy notices if they share information or have changed their policies.
- Review their compliance policies annually.
- Review trades and holdings reports.
For a more complete list of compliance dates for 2021, please see the calendar below.
1 "Large liquidity fund advisers" are not addressed in this alert or in the calendar but are required to file a Form PF amendment within 15 days of the end of the relevant quarter
Originally Published 18 March 2021
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.