WHAT IS HAPPENING?
There are several key deadlines for SEC registered investment advisers in the coming weeks, including form distribution and filings and annual reviews for many. If your firm or fund’s fiscal year ended on 12/31/2019, some dates to keep in mind are as follows:
- Audited financials for private funds are due April 29, 2020.
- Funds of funds have an additional 60 days to distribute to investors.
- Form ADV Part 2 brochure delivery is due April 29, 2020.
- Form CRS can be filed beginning May 1, 2020; the official compliance date is June 30, 2020.
- The Form must be delivered to all existing retail clients within 30 days of when the firm is required to electronically file; the delivery date is July 30, 2020 for firms currently registered with the SEC.
WHAT DOES THIS MEAN FOR ME?
The SEC has issued regulatory relief to provide deadline extensions for COVID-19 affected advisers. Some advisers have accepted relief and will be meeting the extended deadlines instead. It is possible the above items will be impacted by future regulatory relief actions; if this is the case, Fairview will notify you of any changes.
Fairview is continuing to conduct annual reviews and testing for its clients and can assist with data collection, upon request. At this time, the SEC has not issued any relief for delayed annual reviews.
We are committed to remaining fully operational and meeting all normal filing deadlines during this time. Fairview is available to answer questions about upcoming deadlines and how recently instituted regulatory relief may affect your business.