ACA Compliance Group's Danielle Joseph and Anne Wallace contributed the following article to the January 24, 2019 Hedge Fund Law Report.
A new year has begun, and for most hedge fund managers that means the deadline to file the annual updating amendment to Form ADV – a key disclosure document required from SEC-registered investment advisers – is fast-approaching. This seventh installment of the Hedge Fund Law Report’s quarterly compliance update provides tips for fund managers to ensure a smooth process for completing the annual updating amendments to their Forms ADV; highlights upcoming filing deadlines and reporting requirements of which fund managers should be aware during the first quarter; provides a regulatory update to managers investing in digital assets; discusses certain consideration for advisers that engage in quantitative investment strategies; and analyzes the effect of the U.S. government shutdown on SEC-registered investment advisers.
Annual Form ADV Amendment – March 31, 2019
Rule 204-1 under the Investment Advisers Act of 1940 (Advisers Act) requires SEC-registered investment advisers to amend Form ADV annually within 90 days after the end of their fiscal years. Thus, an adviser whose fiscal year ended on December 31, 2018, will be required to file an annual amendment to its Form ADV no later than March 31, 2019. Unless seeking a paper filing “hardship” exemption, advisers must file the annual amendment through the Investment Adviser Registration Depository (IARD) system.