Compliance Corner Q3-2017: Regulatory Filings and Other Considerations That Hedge Fund Managers Should Note in the Coming Quarter

July 20, 2017

The following article, written by ACA's Danielle Joseph and Anne Wallace, appeared in the Hedge Fund Law Report on July 20, 2017.

What issues should hedge fund manager chief compliance officers (CCOs) be focusing on in the third quarter? In addition to completing the various regulatory filings and requirements due at the end of the quarter, CCOs should focus on building out their compliance programs to include forensic testing and other assessments to address internal risks and SEC staff expectations. See “Top Five Compliance Deficiencies in OCIE Risk Alert Include Annual Compliance Reviews, Accurate Regulatory Filings and Custody Issues” (Feb. 23, 2017).
To ensure that fund managers stay on top of the regulatory filings they need to perform each quarter, The Hedge Fund Law Report is introducing this quarterly feature. This first installment highlights some notable regulatory filings fund managers need to perform in the third quarter of 2017. Among the filings addressed herein, fund managers should be particularly mindful of the deadlines and requirements associated with quarterly transaction reports, Form PF, Form ADV and Form 13F in the coming months.
For additional coverage of reporting requirements applicable to fund managers under certain circumstances, see “Marketing and Reporting Considerations for Emerging Hedge Fund Managers” (Jun. 16, 2016); and our two-part series on regulatory reporting by non-E.U. hedge fund managers under E.U. private placement regimes: “Guidance for Registering” (Dec. 3, 2015); and “Roadmap for Reporting” (Dec. 10, 2015).
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