Filing Deadlines and To-Do List for November 2020

INVESTMENT ADVISERS

  • Form 13F: Form 13F quarterly filing for Q3 2020 is due for advisers within 45 days after the end of the calendar quarter. Due date is November 16, 2020.
  • Annual Renewal Program for IARD System: The IARD Renewal Program facilitates the annual renewal of investment adviser (IA) firms and their IA representatives’ (IARs) registrations with jurisdictions/states. Preliminary renewal statements for the IARD system will be available on November 16, 2020, and will be accessible only through the E-Bill System. Renewal statements reflect the registration renewal fees and annual system processing fees for all IARs and state-registered IA firms. The deadline for the receipt of the preliminary statement payment is expected to be on or around December 14, 2020. Questions? Check out the FAQs, which will be updated with 2021 IARD Renewal Program details later in 2020.

HEDGE/PRIVATE FUND ADVISERS

  • 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 November 15, 2020.
  • Form PF for Large Hedge Fund Advisers: Large hedge fund advisers must file Form PF within 60 days of each quarter-end on the IARD system. Due date is November 29, 2020.

REGISTERED COMMODITY POOL OPERATORS & COMMODITY TRADING ADVISORS

  • Form CPO-PQR (September 30 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 November 30, 2020.
  • Form CTA-PR (September 30 Quarter End). Commodity Trading Advisors are required to file Form CTA-PR quarterly with the NFA. Due date is November 16, 2020.

BROKER-DEALERS

  • FINRA 2021 Renewal Program Preparations: Consult the FINRA website to access important dates and information regarding the 2019 Renewal Program. Be sure to update your calendars and ensure your Renewal Account is sufficiently funded.
  • Form OBS: For the Quarter ending September 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 November 2, 2020.
  • Rule 17a-5 Monthly and Fifth FOCUS Part II/IIA Filings: For the period ending October 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 November 25, 2020.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of September 30. 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 November 29, 2020.
  • Annual Audit Reports for Fiscal Year-End September 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 November 30, 2020.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of October 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 November 30, 2020.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of April 30, 2019. 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 November 30, 2020.

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 November 7, 2020.

Photo Credit: Photo by Joseph Gonzalez on Unsplash

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Hardin Compliance Consulting LLC
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