Compliance Corner Q4‑2023: Regulatory Filings and Other Considerations That Hedge Fund Managers Should Note in the Coming Quarter

The end of the calendar year can be a busy time for hedge fund managers. For example, they may be wrapping up the ends of their fiscal years, making various tax elections, arranging for custody rule audits, conducting annual compliance reviews, making required regulatory filings, handling year-end redemptions, calculating fund expenses and conducting performance reviews of their employees. Thus, it is never too soon to start planning for the tasks that lie ahead in the last quarter of the year. This twenty-sixth installment of the Hedge Fund Law Report’s quarterly compliance update highlights upcoming filing deadlines and reporting requirements that fund managers should be aware of during the fourth quarter. This guest article by ACA Group consultants Grazia Gatti, Valerie Speare and Dan Campbell also includes information on an SEC proposal to address risks to investors from conflicts of interest associated with the use of certain technologies – comments on which are due by October 10, 2023 – the release of the SEC’s Spring 2023 Unified Agenda of Regulatory and Deregulatory Actions and a recent SEC enforcement matter concerning alleged naked short selling. For coverage of an ACA Group program, see “Understanding and Mitigating Risks of Using ChatGPT and Other AI Systems” (Jul. 6, 2023).

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