Filing Deadlines and To-Do List for January 2020

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INVESTMENT MANAGERS AND HEDGE/PRIVATE FUND ADVISERS

  • 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, 2019. (Note: Neither the SEC nor its staff has provided guidance on the definition of “promptly” for Form 13H.)
  • 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 January 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 January 15, 2020.
  • Final Renewal Statement: Final statements will be released on January 2, 2020. Download your final renewal statement and arrange for payment of any additional fees as needed by January 17, 2019.

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 4th Quarter, 2019. 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, 2020.
  • Final Renewal Payment: Full payment of your FINRA 2020 Final Renewal Statement is due January 17, 2020.
  • FINRA Contact System Annual Review: FINRA Rule 4517 requires Firms to review and, if necessary, update the required FINRA Contact System information within the first 17 business days of each calendar year. Due January 24, 2020.
  • 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 thereafter. Due January 24, 2020.
  • Quarterly FOCUS Part II/IIA Filings: For Quarter ending December 31. SEC requires that member firms file a FOCUS, (Financial and Operational Combined Uniform Single) Report Part II or IIA on a quarterly basis. Clearing firms and firms that carry customer accounts file Part II and introducing firms file Part IIA. Due January 27, 2020.
  • Annual FOCUS Schedule I Filing for 2019: SEC requires all broker-dealers to submit operational information as of December 31st via the Annual FOCUS Schedule 1 Filing. Due January 27, 2020.
  • Quarterly Form Custody: SEC requires that member firms file Form Custody pursuant to Securities Exchange Act Rule 17a-5(a)(5) for the quarter ending December 31. Due January 27, 2020.
  • Annual Audit Reports for Fiscal Year-End November 30, 2019: SEC 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 January 29, 2020.
  • SIPC-7 Assessment: For firms with a Fiscal Year-End of November 30, 2019. 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, 2020.
  • Supplemental Statement of Income (“SSOI”): For the quarter ending December 31, 2019. 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 January 30, 2020.
  • Supplemental Inventory Schedule (“SIS”): For the month ending December 31, 2019. 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 January 30, 2020.
  • 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, 2020.
  • 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, 2020.

Photo Credit: Photo by J A N U P R A S A D on Unsplash

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