Filing Deadlines and To-Do List for May 2021

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Tasks, Plan, Target, List, Checklist, Organization

INVESTMENT ADVISERS

  • Form 13F: Form 13F quarterly filing is due for Q1 2021 within 45 days after the end of the calendar quarter. Due date is May 17, 2021.
  • Annual Entitlement User Account Certification. FINRA requires broker-dealers and advisers to conduct an annual review of its IARD user accounts and certify 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. Only the SAA has access to this certification, and failure to complete the certification timely will result in the suspension of all user accounts associated with the firm until the certification is complete. The 2021 certification period is April 19-July 19, 2021.
  • ERISA Schedule C of Form 5500 Disclosure: An adviser may be required to report certain information to its ERISA plan clients and investors for their use in completing Department of Labor Form 5500, including details about compensation received concerning ERISA plan assets that the adviser manages or that are invested in the adviser’s funds. If you have ERISA plan clients that follow a calendar year, they may request this information to file Form 5500 by July 31, 2021. (ERISA plan clients that do not follow a calendar year must submit Form 5500 by the last day of the seventh month following the plan’s year-end.)

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 May 15, 2021.
  • 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 May 30, 2021.

BROKER-DEALERS

  • Annual Entitlement User Account Certification. FINRA requires firms to conduct an annual review of the FINRA application user accounts established for firm personnel and ensure that access and entitlements are appropriate for the personnel’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 WebCRD. Only the SAA has access to this certification. Failure to complete the certification by the established deadline will result in all user accounts associated with the firm to be suspended until the certification is complete. The 2021 certification period is April 19-July 19, 2021.
  • Rule 17a-5 Monthly and Fifth FOCUS Part II/IIA Filings. For the period ending April 30, 2021. For firms required to submit monthly FOCUS filings and those firms whose fiscal year-end is a date other than a calendar quarter. Due May 25, 2021.
  • Supplemental Inventory Schedule (“SIS”). For the month ending April 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 May 28, 2021.
  • SIPC-6 Assessment. For firms with a Fiscal Year-End of October 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 May 30, 2021.
  • SIPC-7 Assessment. For firms with a Fiscal Year-End of March 31st. 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 May 30, 2021.
  • SIPC-3 Certification of Exclusion from Membership. For firms with a Fiscal Year-End of April 30th, 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 May 31, 2021.

REGISTERED COMMODITY TRADING ADVISORS

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 May 7, 2021.
  • Form N-PORT. Funds with a fiscal quarter end of March 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. Due date is May 30, 2021. 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 Credit: Image by 11066063 from Pixabay.

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