Compliance Corner Q3‑2019: Regulatory Filings and Other Considerations That Hedge Fund Managers Should Note in the Coming Quarter

The SEC has repeatedly demonstrated how seriously it takes an investment adviser’s obligation to make timely and accurate filings, as evidenced by the Commission’s filings-centric examination sweeps and subsequent enforcement actions. In addition, the SEC staff also uses forensic tools to identify advisers that should be making required filings but have not done so. The actions taken by the SEC serve as a clear reminder that hedge fund managers should ensure they identify and complete all filings required of them and the private funds they control. This ninth installment of the Hedge Fund Law Report’s quarterly compliance update, authored by consultants Anne Wallace, John Mrakovcic and Chris Ray at ACA Compliance Group, highlights upcoming filing deadlines for the third quarter and discusses certain filing obligations of fund managers and their private funds. In addition to the upcoming filing requirements, this article discusses the Regulation S‑P Risk Alert and Network Storage Risk Alert recently issued by the Commission in April and May, respectively. For more on Regulation S‑P, see “SEC Officials Flesh Out Cybersecurity Enforcement and Examination Priorities (Part One of Two)” (May 11, 2017).

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