Now that 2016 is firmly upon us, a number of United States regulatory filing deadlines come into view, particularly for firms with a 31 December fiscal year end (“FYE”). The chart below lists important filing requirements and corresponding 2016 filing deadlines. A pdf version is available here.
To find out more information about year end United States filing requirements and their applicability contact Complyport’s International Desk at +44 (0)20 7399 4980 or info@complyport.co.uk.
| Filing/Requirement | Ongoing Deadlines | 2016 Date (FYE December 31) | Notes |
| Form ADV Parts 1 and 2A Annual Updates | Parts 1 and 2A annual updates must be filed within 90 days of adviser’s fiscal year end electronically on IARD | Wednesday, 30 March 2016 | Exempt Reporting Advisers only need to file Part 1 of Form ADV |
| Form PF Updates |
Large Hedge Fund Advisers and Large Liquidity Advisers must update quarterly
All other advisers must updated annually
Part 1: Must update annually within 120 days of FYE
Part 2: Must update quarterly within 60 days of the end of each fiscal quarter
Part 3: Must update quarterly within 15 days of the end of each fiscal quarter
Part 4: must update annually within 120 days of FYE
|
Friday, 29 April 2016
Monday, 29 February 2016
15 January, 15 April, 15 July, 15 October
Friday, 29 April 2016
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| Form D Update | Federal Form D – Annually if making a continuing offering in reliance on Regulation D on each anniversary of the date of initial filing | Depends on initial filing date |
Must update promptly following any material change to the Form D
State “blue sky” filings – Form D may need to be filed at the state level following admission of new US investors
|
| Schedule 13D | No annual update required | Not applicable | Material changes (+/- 1%) must be filed promptly (typically 1 business day) |
| Schedule 13G | Annual update due 45 days after calendar year end | Monday, February 15 2016 (14 February = Sunday) | |
| Schedule 13F |
Initial filing update required within 45 days of the end of each calendar year in which investor exceeds the $100 million threshold
Quarterly filing updates required within 45 days of the end of each calendar quarter once threshold is crossed
|
Monday, February 15 2016 (14 February = Sunday)
15 May 2016; 14 August 2016; 14 November 2016
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| Schedule 13H “Large Trader Reporting” |
Annual updates must be filed 45 days after calendar year end | Monday, February 15 2016 (14 February = Sunday) | If the trader did not conduct aggregate transactions during the prior full calendar year that crossed the thresholds, it can file for “inactive status” |
| CFTC/NFA Registration Update | Annually by the firm’s CFTC/NFA registration anniversary date with the NFA | Depends on CFTC/NFA registration anniversary date (which can be checked on NFA BASIC) | |
| NFA Questionnaire | Annually within 12 months of the firm’s last self-examination | Depends on firm’s last self-examination date | |
| Form CPO-PQR & NFA-PQR |
Quarterly with the NFA within 90 days of the calendar year end
Large CPOs (more than $1.5 billion AUM) within 60 days of the end of the three subsequent calendar quarters
|
Wednesday, 30 March 2016
Monday, 29 February 2016
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| Form CTA-PR & NFA PR | Quarterly with the NFA within 45 days of the end of each calendar quarter | ||
| CFTC Exemption Renewals | Annually within 60 days after each calendar year end | Monday, 29 February 2016 |
