Filing Deadlines and To-Do List for June 2020

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INVESTMENT MANAGERS

  • GIPS Notification Requirement: Firms opting to comply with the Global Investment Performance Standards (GIPS) must notify the CFA Institute of its claim of compliance on an annual basis. This notification is due June 30, 2020, and should be submitted by completing the appropriate online form for on the CFA Institute’s website.
  • Form CRS: Advisers to Retail Clients must file initial Form CRS as ADV Part 3 via IARD by June 30, 2020. Advisers must also begin delivering Form CRS to all new and prospective retail clients on this date. Refer to Hardin’s dedicated Regulation Best Interest (Reg BI) page for templates and additional information.
  • Annual Entitlement User Certification: FINRA requires firms to conduct an annual review of its IARD user accounts and ensure that access and entitlements are appropriate for each user’s role and responsibilities. The Super Account Administrator (“SAA”) is responsible for conducting the review, amending and deleting user accounts/entitlements as necessary, and submitting the certification through IARD. Only the SAA has access to this certification, and a Quick Reference Guide to the entitlement process is available on the IARD site. This year, the certification period opened on April 20th and must be completed by July 20, 2020.

HEDGE/PRIVATE FUND MANAGERS

  • Blue Sky Filings (Form D): Advisers 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. Did you know that Hardin Compliance Consulting offers a convenient and economical blue-sky filing service to help firms manage this complicated monthly task? Learn more here and give us a call to discuss your needs further. Due June 15, 2020.
  • Distribute Audited Financial Statements for Private Funds: Funds of Funds: Private fund investment advisers should have their funds audited by an independent, PCAOB-registered accountant and deliver the audited financial statements to the funds’ investors within 120 days of the end of the funds’ fiscal year. The deadline for private funds that are fund of funds is 180 days of the funds’ fiscal year-end. That’s June 29, 2020, for funds with December 31 year-end.

BROKER-DEALERS (* FILING EXTENSIONS MAY BE AVAILABLE)

  • Annual Audit Reports for Fiscal Year-End March 31, 2020: FINRA requires that member firms submit their annual audit 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 June 1, 2020.
  • Rule 17a-5 Monthly and Fifth FOCUS Part II/IIA Filings*: For the period ending May 31, 2020. For firms required to submit monthly FOCUS filings and those firms whose fiscal year-end is a date other than a calendar quarter. Due June 23, 2020.
  • Supplemental Inventory Schedule (“SIS”)*: For the month ending May 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 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 June 26, 2020.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of April 30, 2019. 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 June 29, 2020.
  • Annual Audit Reports for Fiscal Year-End April 30, 2020: FINRA requires that member firms submit their annual audit 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 June 29, 2020.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of May 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 June 30, 2020.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of November 30. 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 June 30, 2020.
  • Form CRS Relationship Summary: Form CRS and its related rules require SEC-registered investment advisers and SEC-registered broker-dealers to deliver to retail investors a brief customer or client relationship summary that provides information about the firm. Firms must file their relationship summaries with the Commission. Due June 30, 2020.
  • Annual Entitlement User Account Certification: FINRA requires firms to conduct an annual review of the FINRA application user accounts established for firm personnel and ensure that access and entitlements are appropriate for the personnel’s role and responsibilities. The Super Account Administrator (“SAA”) is responsible for conducting the review, amending and deleting user accounts/entitlements as necessary, and submitting the certification through WebCRD. Only the SAA has access to this certification. Notifications were delivered to the SAAs on or around April 20th. Due July 20, 2020.

REGISTERED COMMODITY POOL OPERATORS

  • Form CPO-PQR (March 31 Quarter End): Small, Mid-Sized and Large Commodity Pool Operators are required to file NFA Form CPO-PQR quarterly with the NFA. The due date is May 30, 2020. No action relief extending this due date is available – see NFA Notice I-20-15 for details.

MUTUAL FUND ADVISERS

  • Form N-PORT (Large Fund Complexes): Large fund families (those with greater than $1 billion in assets) must file Form N-PORT reporting month end information for each month-end in each fiscal quarter no later than 60 days after fiscal quarter-end. For funds with a March 31 fiscal quarter end, the due date is June 1, 2020. Funds must also prepare the information reported on Form N-PORT within 30 days after every month-end and retain these records, which are subject to SEC inspection.
  • 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 June 5, 2020.
  • Form N-PORT (Small Fund Complexes, March 31 Fiscal Quarter End): Small fund families (those with less than $1 billion in assets) with a fiscal quarter end of March 31, must file Form N-PORT reporting month end information for each month-end in each fiscal quarter no later than 60 days after fiscal quarter-end. In this initial filing, Form N-PORT funds need only report information for the month ending March 31, 2020. Due date is June 1, 2020. Funds must also prepare the information reported on Form N-PORT within 30 days after every month-end and retain these records, which are subject to SEC inspection.
  • Form N-PORT (Small Fund Complexes, April 30 Fiscal Quarter End): Small fund families (those with less than $1 billion in assets) with a fiscal quarter end of April 30, must file Form N-PORT reporting month end information for each month-end in each fiscal quarter no later than 60 days after fiscal quarter-end. In this initial filing, Form N-PORT funds need only report information for the months of March and April 2020. Due date is June 29, 2020. Funds must also prepare the information reported on Form N-PORT within 30 days after every month-end and retain these records, which are subject to SEC inspection.

Photo Credits: Photo by Domenico Loia on Unsplash.

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