Annual Deadlines for Certain Regulated Entities

During the first quarter of each year, there are a number of filings that are required by certain regulated advisers.

Outlined below is a list of regulatory requirements.

February 15, 2016 – Form 13H
Investment advisers that are deemed to be “large traders” are required to file an “Annual Filing” to the Form 13H within 45 days after the end of the calendar year.

February 15, 2016 – CFTC CTA-PR Filing
Registered commodity trading advisors (“CTAs”) are required to complete the U.S. Commodity Futures Trading Commission’s (“CFTC”) CTA-PR filing within 45 days after the fiscal year-end through the NFA’s EasyFile System.

February 29, 2016 – Affirmation of Certain CFTC Exemptions
The CFTC requires entities to annually affirm certain CFTC registration exemptions, including Regulation 4.13(a)(3), 4.5 and 4.14(a)(8). Such exemptions are required to be reaffirmed within 60 days of the calendar year-end through the NFA Exemption website. Failing to complete the affirmations will be deemed as a request to withdraw such exemption(s).

February 29, 2016 – CFTC CPO-PQR Filing for Large CPOs
Registered large commodity pool operators (“CPOs”), with assets under management (“AUM”) exceeding $1.5 billion, are required to complete the CFTC’s CPO-PQR filing within 60 days after fiscal year-end through the NFA’s EasyFile System.

March 30, 2016 – Registered CPO Requirements 
Registered CPOs are required to upload pool financial statements with the NFA through the EasyFile System and distribute the statements to pool participants on an annual basis within 90 days of fiscal year-end. Extensions for this filing and distribution deadline may be available under certain circumstances.

March 30, 2016 – CFTC CPO-PQR Filing for Small and Mid-Size CPOs
Registered small and mid-size CPOs (AUM of less than $150 million and AUM between $150 million and $1.5 billion respectively) are required to complete the CFTC’s CPO-PQR filing within 90 days after fiscal year-end through the NFA’s EasyFile System.

March 30, 2016 – Annual Updating Amendment to the Form ADV
On at least an annual basis, advisers are required to file their Annual Updating Amendment to the Form ADV within 90 days of the adviser’s fiscal year-end through the IARD system.

If you have any questions regarding any of the aforementioned deadlines, please contact us.

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