Filing Deadlines and To-Do List for October 2021

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INVESTMENT ADVISERS

  • Form 13H: Amendment to Form 13H due promptly for advisers that already have a Form 13H filing obligation and have changes to any information reported. Recommended due date: October 13, 2021. (Note: Neither the SEC nor its staff has provided written guidance defining “promptly” for Form 13H.)

HEDGE/PRIVATE FUND ADVISERS

  • 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. Filing for Q3 2021 is due October 15, 2021.
  • 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 October 15, 2021.

BROKER-DEALERS

  • 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 third quarter. FINRA Rule 4530 requires member 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 October 15, 2021.
  • Quarterly FOCUS Part II/IIA Filings: For the quarter ending September 30, 2021. FINRA requires member firms to 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 Date October 26, 2021.
  • Quarterly Form Custody: SEC requires that all broker-dealers file Form Custody under Securities Exchange Act Rule 17a-5(a)(5) for the quarter ending September 30, 2021. Due Date October 26, 2021.
  • Supplemental Statement of Income (“SSOI”): For the quarter ending September 30, 2021. FINRA requires member 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 October 29, 2021.
  • Supplemental Inventory Schedule (“SIS”): For the month ending September 30, 2021. 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 October 29, 2021.
  • SIPC-3 Certification of Exclusion from Membership: For firms with a Fiscal Year-End of September 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 October 30, 2021.
  • SIPC-6 Assessment: For firms with a Fiscal Year-End of March 31. SIPC members must 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 October 30, 2021.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of August 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 FYE. Due October 30, 2021.

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. The due date is October 7, 2021.

Photo Credit: Image by 11066063 from Pixabay.

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