Every year at this time, registered investment advisers are — or should be — thinking about some of the annual regulatory compliance requirements imposed by the Securities and Exchange Commission.
Yet every year, we are contacted by advisers who either don’t know exactly what they need to file, haven’t done it or haven’t invested the resources to do it right. This often leads to big mistakes that can be very time-consuming and costly to undo.
Outlined below are three important Q1 and early Q2 compliance requirements, including notable areas where managers need to take extra care to get it right:
1. Form ADV. This is the big one. For private fund managers, Form ADV has specific disclosure requirements about the private funds themselves, from questions about investors, source of investments and capital commitments to the funds’ service providers, where one minor change during the reporting year can alter the entire picture that is presented to the SEC. It is critical to ensure that every “i” is dotted and “t” is crossed according to regulatory standards.