| --- |
| title: "House Oversight: Estate Documents (Nov 12) (HOUSE_OVERSIGHT_019861)" |
| source: "House Oversight: Estate Documents (Nov 12)" |
| sourceUrl: "https://www.justice.gov/epstein" |
| date: "2026-01-01" |
| category: "House Oversight" |
| eftaNumber: "HOUSE_OVERSIGHT_019861" |
| ocrPages: 1 |
| ocrChars: 6574 |
| ocrElapsed: 0.0 |
| parseTier: "external-legacy" |
| engine: "engine undisclosed (ep-nov-12.greg.technology mirror)" |
| externalSource: "greg-ep-nov-12" |
| externalLicense: "not granted" |
| externalCredit: "ep-nov-12.greg.technology" |
| externalUrl: "https://ep-nov-12.greg.technology" |
| --- |
| |
| COMPLIANCE DEADLINES - Second Quarter 2017 |
| There are many regulatory filings and compliance forms that investment managers need to complete throughout the year. Below is a list of some of the key com- |
| pliance dates for the second quarter of 2017. Please note that this is general advice that is applicable to most investment advisers with a December 31st fiscal |
| year end. This list is not exhaustive and contains some best practice compliance suggestions. |
| DATE |
| April 1 |
| April 10 |
| April 15 |
| April 30 |
| May 15 |
| May 30 |
| May 31 |
| ACTIVITY |
| ERISA Schedule C of Form 5500 Disclosure. Adviser may be |
| required to report certain information to its ERISA plan clients |
| and investors for their use in completing Department of Labor |
| Form 5500. |
| Form 13H. Form 13H (large trader) quarterly filing is due for |
| Q1 2017 for advisers that already have Form 13H filing obligation |
| and have changes to any of the information reported. |
| Form PF for Large Liquidity Fund Advisers. Large liquidity |
| fund advisers must file Form PF with the U.S. Securities and |
| Exchange Commission ("SEC") on the IARD system within 15 |
| days of each fiscal quarterly end. |
| Brokerage Committee Meeting. Conduct quarterly brokerage |
| committee meeting. |
| Private Fund Audited Financial Statements. Distribute audited |
| financial statements to investors for any private investment fund |
| for which the adviser or a related person has custody of the fund's |
| assets, assuming the adviser is registered with the SEC or a |
| state authority. |
| Annual Delivery of Form ADV Part 2. Send to all clients and fund |
| investors a copy of the adviser's Form ADV Part 2, assuming the |
| adviser is registered with the SEC or a state authority.! |
| U.S. FATCA Notification Deadline. Deadline by which all Cayman |
| Financial Institutions ("Fls") and Non Reporting Fls are required to |
| make certain notifications as to their Common Reporting Standard |
| ("CRS") reporting status to the Cayman Islands Tax Information |
| Authority (the "TIA"), as the jurisdiction's competent authority |
| for purposes of the CRS. |
| Access Person Quarterly Transaction Reports. Collect quarterly |
| reports from access persons for their personal securities transactions. |
| Code of Ethics and Compliance Manual. Distribute code of ethics |
| and compliance manual to employees, including acknowledgment form. |
| Annual Filers - Form PF with SEC. Private equity funds and |
| smaller private fund advisers with a December 31st fiscal |
| year end, assuming the adviser is registered with the SEC. |
| Form 13F. File any required Form 13F with the SEC. |
| Privacy Policy Notices. Send an annual privacy notice to every |
| natural person client or fund investor, which could be included |
| with the delivery of Form ADV Part 2 to clients and fund investors.? |
| Form PF for Large Hedge Fund Advisers. Large hedge fund |
| advisers must file Form PF within 60 days of each quarter end on the |
| IARD system. |
| U.S. FATCA Reporting Deadline. First reporting date deadline to |
| the Cayman Island TIA in respect of Reportable Accounts for |
| reporting year 2016. It is necessary for Cayman Reporting Fls to |
| provide a NIL report where they have no Reportable Accounts. |
| S&G INVESTME |
| DATE |
| June 15 |
| June 30 |
| Anniversary |
| Date of Filing |
| As Necessary |
| ACTIVITY |
| Quarterly Employee Compliance Training. Conduct a quarterly |
| employee training session to review requirements under the |
| adviser's written compliance policies and procedures, including |
| the code of ethics, as well as any material changes to these |
| materials. Maintain list of attendance.3 |
| Form 13H. Review transactions and assess whether Form 13H |
| needs to be amended. |
| Form PF. Review assets/holdings to determine filing requirements. |
| PQR (For Registered Commodity Pool Operators). Small and |
| mid-sized CPOs quarterly reports to be filed using NFA Easy |
| File System. |
| CRS Notifications. The Cayman Islands TIA announced a |
| soft opening for the first year of the CRS. CRS registrations |
| will be accepted up to June 30, 2017 (original deadline was |
| April 30, 2017). |
| Annual Form D. Amendment due on or before anniversary date of |
| prior Form D filing(s). |
| CPO/CTA Questionnaires. Due on or before anniversary date, |
| and promptly when material information changes. |
| Schedule 13D. Must be filed within 10 days after acquisition of |
| beneficial ownership of 5% of a voting class of a company's equity |
| securities registered under Section 12 of the Securities Exchange |
| Act of 1934. See: https://www.sec.gov/answers/sched13.htm |
| Forms 3, 4 & 5 (Sec 16 Filings). Corporate insiders-meaning |
| a company's officers and directors, and any beneficial owners of |
| more than 10% of a class of the company's equity securities |
| registered under Section 12 of the Securities Exchange Act of |
| 1934—must file with the SEC a statement of ownership regarding |
| those securities. See: https://www.sec.gov/answers/form345.htm |
| Bureau of Economic Analysis Filings ("BEA") (BE-11, BE-13, |
| BE-577, etc.). Should the BEA contact you via letter or |
| otherwise, you are required to respond to this inquiry by law. |
| Please contact us should the BEA contact you to discuss. A Form |
| BE-577 is required from every U.S. person who had direct |
| transactions or positions with a foreign business enterprise in |
| which it had a direct and/or indirect ownership interest of at least |
| 10% of the voting stock if an incorporated business enterprise or |
| an equivalent interest if an unincorporated business enterprise |
| at any time during the reporting period. |
| 1 An adviser is required to deliver Form ADV Part 2 to clients; it is not required to deliver Form ADV |
| Part 2 to investors in a pooled investment vehicle. However, it is considered a best practice and it is |
| recommended that an adviser delivers Form ADV Part 2 to each investor in a pooled investment vehicle. |
| 2 Although Regulation S-P does not specify the exact day by which the annual privacy notice must |
| be sent, May 30 seems to be an appropriate date because the mailing can be coordinated with |
| delivery of Form ADV Part 2 (which can include the Privacy Policy) to clients or fund investors. |
| 3 The Investment Advisers Act of 1940 does not specify that any training session is necessary, and |
| therefore the date on which training should occur is not specified. However, a registered adviser |
| must distribute and receive signed acknowledgements of changes to its code of ethics. Since the |
| code (as well as an adviser's compliance policies and procedures) may be amended as part of |
| an adviser's annual review, as well as at any other time, quarterly training should help to keep |
| personnel up-to-date regarding policies and procedures and otherwise remind personnel of their |
| compliance obligations. |
| T MANAGER ALERT |
| 6 |
| HOUSE_OVERSIGHT_019861 |
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