May 26, 2020

Annual Compliance Obligation Reminders

Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the U.S. Commodity Futures Trading Commission are subject to important annual compliance obligations. This summary sets forth the primary obligations of which your firm should be aware. This summary should not be considered an exhaustive list of your firm’s obligations under the broader federal securities laws, tax laws or applicable state, local or foreign laws. Obligations for state-registered Advisers may vary from SEC obligations and clients should feel free to contact us for more information.

List of annual compliance deadlines for Advisers

List of Annual Compliance Deadlines for Advisers

Important Notice for 2018 Form ADV Filers

Beginning on October 1, 2017, all advisers filing Form ADV are required to use an updated version of Form ADV Part 1 that contains several new items. Among other items, the updated form (i) requires increased disclosures for advisers to separately managed accounts, (ii) streamlines the registration process for multiple private fund advisers operating as a single advisory business and (iii) requires enhanced disclosures regarding certain business practices, including information regarding an adviser’s online presence and financial industry affiliations. For advisers with a December 31 fiscal year end that have not made an other-than-annual amendment to Form ADV since October 1, 2017, the annual update due in March 2018 will be the first filing under the updated form. Advisers should allot additional time to complete the updated form this year to allow sufficient time to assess the impact of new items and undertake potentially significant data collection efforts to satisfy the new form requirements. The new requirements impact investment advisers with separately managed accounts in particular. 

Obligations for Private Fund Advisers

Obligations for Private Fund Advisers

Obligations for CTAs

Obligations for CTAs

Obligations for CPOs

Obligations for CPOs

Tax, Treasury and Other Filings


Jeff VonDruska contributed to this article. 

© 2020 Vedder Price


About this Author

Deborah Bielicke Eades, Vedder Price Law Firm, Finance Attorney

Deborah Bielicke Eades joined Vedder Price P.C. as a shareholder and is a member of the firm’s Investment Services Group.

Ms. Eades has extensive experience in all aspects of mutual fund and investment adviser regulation and compliance, including product design, federal and state registration, representation of fund boards, portfolio compliance, derivative instruments, affiliated transactions, electronic commerce and Web site design, privacy matters and general regulatory matters.

Joseph Mannon, Investment Lawyer, Vedder Price Law Firm

Joseph M. Mannon is a member of Vedder Price P.C.’s Investment Services group.

Mr. Mannon focuses his practice on legal and compliance matters for investment advisers, mutual funds, closed-end funds and unregistered vehicles such as hedge funds, hedge fund of funds and other investment entities.  With regard to unregistered vehicles, he frequently counsels clients on fund formation and structuring matters for funds organized both in the United States and abroad.  He also counsels clients on issues relating to commodity trading advisers and commodity pool operators.