Investment advisers registered with the Securities and Exchange Commission (the SEC) (each, an RIA) are subject to certain annual requirements under the Investment Advisers Act of 1940 (the Advisers Act); some of these requirements also either apply to exempt reporting advisers (each, an ERA) or warrant consideration as best practices for ERAs. This Sidley Update alerts investment advisers to certain annual regulatory and compliance obligations, including a number of significant 2019 reporting or filing deadlines.
This Sidley Update also reminds advisers that are registered as commodity pool operators (CPOs) or commodity trading advisors (CTAs) with the Commodity Futures Trading Commission (the CFTC) and members of the National Futures Association (the NFA) of certain CFTC and NFA reporting requirements.
This Sidley Update provides important information regarding
- Annual Form ADV Updating Requirements
- Compliance Program Review and Testing
- Other Annual Reminders for RIAs and ERAs
- SEC Examination Priorities for 2019
- Preparing for an SEC Exam
- Recent Regulatory Developments and Guidance
- SEC Focus on Digital Assets and ICOs
- Recent SEC Enforcement Proceedings
- Form PF Reporting Requirements
- CFTC and NFA Reporting Requirements for Certain Investment Advisers
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Sidley provides this information as a service to clients and other friends for educational purposes only. It should not be construed or relied on as legal advice or to create a lawyer-client relationship. Readers should not act upon this information without seeking advice from professional advisers. Sidley and Sidley Austin refer to Sidley Austin LLP and affiliated partnerships as explained at www.sidley.com/disclaimer.
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