Filing Deadlines and To-Do List for September 2021

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HEDGE/PRIVATE FUND ADVISORS

  • Blue Sky Filings (Form D). Advisors to private funds should review fund blue sky filings and determine whether any amended or new filings are necessary. Generally, most states require a notice filing (“blue sky filing”) within 15 days of the first sale of interests in a fund, but state laws vary. Due September 15, 2021.

BROKER-DEALERS

  • Rule 17a-5 Monthly and Fifth FOCUS Part II/IIA Filings: For the period ending August 31. Filing required for firms required to submit monthly FOCUS filings and those firms whose fiscal year-end is a date other than a calendar quarter. Due September 24, 2021.
  • Supplemental Inventory Schedule (“SIS”): For the month ending August 31. The SIS must be filed by a firm that is required to file FOCUS Report Part II, FOCUS Report Part IIA, or FOGS Report Part I, with inventory positions as of the end of the FOCUS or FOGS reporting period, unless the firm has (1) a minimum dollar net capital or liquid capital requirement of less than $100,000; or (2) inventory positions consisting only of money market mutual funds. A firm with inventory positions consisting only of money market mutual funds must affirmatively indicate through the eFOCUS system that no SIS filing is required for the reporting period. Due September 29, 2021.
  • Annual Reports for Fiscal Year-End July 31, 2021: FINRA requires that member firms submit their annual reports in electronic form. Firms must also file the report at the regional office of the SEC in which the firm has its principal place of business and the SEC’s principal office in Washington, DC. Firms registered in Arizona, Hawaii, Louisiana, or New Hampshire may have additional filing requirements. Due September 29, 2021.
  • SIPC-7 Assessment: For firms with a fiscal year-end of July 31. SIPC members are required to file the SIPC-7 General Assessment Reconciliation Form together with the assessment owed (less any assessment paid with the SIPC-6) within 60 days after the Fiscal Year-End. Due September 29, 2021.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a fiscal fear-end of August 31 AND claiming an exclusion from SIPC Membership under Section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970. This annual filing is due within 30 days of the beginning of each fiscal year. Due September 30, 2021.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of February 29. SIPC members are required to file for the first half of the fiscal year a SIPC-6 General Assessment Payment Form together with the assessment owed within 30 days after the period covered. Due September 30, 2021.

MUTUAL FUNDS

  • Form N-MFP. Form N-MFP (Monthly Schedule of Portfolio Holdings of Money Market Funds) reports information about the fund’s holdings as of the last business day of the prior calendar month and must be filed no later than the fifth business day of each calendar month. Due date is September 8, 2021.

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