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Consider starting Annual Compliance Review (if not already completed for the year)

Reference: SEC Guidance

Transmit or confirm broker-dealer has transmitted client quarterly statements

Happy New Year!

From all of us to all of you, our best wishes for a Happy and Prosperous New Year! And thanks for your continuing support.

SEC Investor Bulletin: Investment Adviser Sponsored Wrap Fee Programs

In early December the SEC published an Investor Bulletin updating and outlining the basics of wrap fee programs from an investor’s perspective. The Bulletin is instructive on the SEC’s current advice and views of such programs, which are growing rapidly. Notably at the end of the Bulletin the SEC references…

Adviser with custody must arrange for audit

Verify that Annual Review required by Rule 206(4)-7 is complete

Small and Mid-Sized Commodity Pool Operators are required to file NFA Form CPO-PQR

Large CPOs file Form CPO-PQR with the NFA

Large hedge fund advisers must file Form PF within 60 days of each quarter end on the IARD system