Filing Deadlines and To-Do List for January 2022



  • Form 13H: Amendments to Form 13H are due promptly if there are any changes to information for Form 13H Filers. The SEC’s “Frequently Asked Questions Concerning Large Trader Reporting,” response 2.5 says Form 13H Filers may file an amendment and an annual amendment together if any changes occurred during the fourth quarter to the information contained in Form 13H. Amendments are due “promptly,” which we interpret as within ten days. Recommended due date: January 10, 2022. (Note: Neither the SEC nor its staff has provided guidance on the definition of “promptly” for Form 13H.)
  • Final Renewal Statement: Final statements will be released on January 2, 2022. Download your final renewal statement and arrange for payment of any additional fees as needed by January 28, 2022.


  • 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 January 15, 2022.
  • 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. For funds with a December 31 fiscal quarter end, Form PF is due January 15, 2022.


  • FINRA Accounting Support Fee: Firms receive a 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. Payments are sent to the firm via WebCRD’s E-Bill. Due January 15, 2022.
  • Customer Complaint Quarterly Statistical Summary: For complaints received during the 4th Quarter. 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 January 15, 2022.
  • Final Renewal Payment: Full payment of your FINRA Final Renewal Statement is due January 28, 2022.
  • FINRA Contact System Annual Review: FINRA Rule 4517 requires Firms to review and, if necessary, update the necessary FINRA Contact System information within the first 17 business days of each calendar year. Due January 25, 2022.
  • MSRB Form A-12 Annual Affirmation. MSRB Rule A-12(k) requires each broker that is a member of the MSRB to review, update as necessary, and affirm the information in Form A-12 during the Annual Affirmation Period that begins on January 1 of each calendar year and ends 17 business days after that. Due January 25, 2022.
  • Quarterly FOCUS Part II/IIA Filings: For Quarter ending December 31, 2021. SEC requires that member firms file a FOCUS (Financial and Operational Combined Uniform Single) Report Part II or IIA every quarter. Clearing firms and firms that carry customer accounts file Part II and introducing firms file Part IIA. Due January 26, 2022.
  • Annual FOCUS Schedule I Filing for Period, 2021: SEC requires all broker-dealers to submit operational information as of December 31st via the Annual FOCUS Schedule 1 Filing. Due January 29, 2022.
  • Quarterly Form Custody: SEC requires that member firms file Form Custody under Securities Exchange Act Rule 17a-5(a)(5) for the quarter ending December 31. Due January 26, 2022.
  • Annual Reports for Fiscal Year-End November 30, 2021: SEC 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 January 29, 2022.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of November 30th. 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 January 29, 2022.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of December 31st 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 January 30, 2022.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of June 30th. 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 January 30, 2022.


  • 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 January 10, 2022.

Photo Credit: Photo by Thomas Bormans on Unsplash.

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