Filing Deadlines and To-Do List for July 2020

Hardin Compliance Consulting LLC
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INVESTMENT MANAGERS

  • Form 13H: Following an initial filing of Form 13H, all large traders must make an amended filing to correct inaccurate information promptly (within ten days) following the quarter-end in which the information became stale. Recommended due date: July 10, 2020. (Note: Neither the SEC nor its staff has provided guidance on the definition of “promptly” for Form 13H)
  • 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.
  • Form CRS: Advisers to Retail Clients (as that term is defined in Regulation Best Interest (Reg BI) must file deliver their Form CRS to all existing retail investors before July 30, 2020. Refer to Hardin’s dedicated Reg BI webpage for templates and additional information.

HEDGE/PRIVATE FUND MANAGERS

  • Form PF for Large Liquidity Fund Advisers: Large liquidity fund advisers must file Form PF with the SEC on the IARD system within 15 days of each fiscal quarter-end. Due date is July 15, 2020.
  • 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. Due July 15, 2020.

BROKER-DEALERS (* FILING EXTENSIONS MAY BE AVAILABLE)

  • FINRA Accounting Support Fee: Quarterly invoice to support the GASB budget. Based on the municipal securities the firm reported to the MSRB. De Minimis firms (that owe less than $25) will not receive an invoice. Invoices are sent to the firm via WebCRD’s E-Bill. Due date to be determined.
  • Customer Complaint Quarterly Statistical Summary: For complaints received during the second FINRA Rule 4530 requires Firms to submit statistical and summary information regarding complaints received during the quarter by the 15th day of the month following the calendar quarter. Due July 15, 2020.
  • Quarterly FOCUS Part II/IIA Filings: For Quarter ending June 30. FINRA requires that member firms file a FOCUS (Financial and Operational Combined Uniform Single) Report Part II or IIA quarterly. Clearing firms and firms that carry customer accounts file Part II and introducing firms file Part IIA. Due July 24,
  • Quarterly Form Custody: SEC requires that member firms file Form Custody under Securities Exchange Act Rule 17a-5(a)(5) for the quarter ending June 30. Due July 24,
  • Supplemental Statement of Income (“SSOI”): For the quarter ending June 30. FINRA requires firms to submit additional, detailed information regarding the categories of revenues and expenses reported on the Statement of Income (Loss) page of the FOCUS Report Part II/IIA. Due July 29,
  • Supplemental Inventory Schedule (“SIS”): For the month ending June 30. 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 July 29, 2020.
  • Annual Audit Reports for Fiscal Year-End May 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 July 30,
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of June 30 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 July 30,
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of December 31. 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 July 30,
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of May 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 July 30,
  • Form OBS: For the Quarter ending June 30. Unless subject to the de minimis exception, all clearing, self-clearing, and carrying firms and those firms that have a minimum dollar net capital requirement equal to or greater than $100,000 and at least $10 million in reportable derivatives and other off-balance sheet items must submit Form OBS as of the last day of a reporting period within 22 business days of the end of each calendar quarter via eFOCUS. Firms that claim the de minimis exemption must affirmatively indicate through the eFOCUS system that no filing is required for the reporting period. Due July 31,

MUTUAL FUND ADVISERS

  • 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 July 7, 2020.
  • Form N-PORT (Small Fund Complexes, May 31 Fiscal Quarter End). Small fund families (those with less than $1 billion in assets) with a fiscal quarter end of May 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 must report information for the months of March, April, and May 2020. Due date is July 30, 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 Nathan Edwards on Unsplash.

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