Filing Deadlines and To Do List for June 2018

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FOR HEDGE/PRIVATE FUND MANAGERS

  •  Distribute Audited Financial Statements for Private Funds for 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 within 180 days of the funds’ fiscal year end. That’s June 29, 2018 for funds with December 31 year-end.

FOR BROKER DEALERS

  • Rule 17a-5 Monthly and Fifth FOCUS Part II/IIA Filings:  For period ending May 31, 2018. 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 25, 2018. 
  • Supplemental Inventory Schedule (“SIS”): For the month ending May 31, 2018. 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 28, 2018.
  • Annual Audit Reports for Fiscal Year-End April 30, 2018:  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, 2018.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of April 30, 2018.  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, 2018.

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