Compliance Corner Q1‑2020: Regulatory Filings and Other Considerations That Hedge Fund Managers Should Note in the Coming Quarter

For most hedge fund managers, the first quarter in the new year is the time to update Form ADV; finalize and deliver an updated compliance manual to employees; and collect employees’ annual disclosures and personal holdings reports. Fund managers will also have to consider the California Consumer Privacy Act of 2018, which took effect on January 1, 2020; creates new consumer rights related to the access, deletion and sharing of personal information collected by businesses; and requires implementation of policies and procedures to address, among other things, protection of personal information, privacy, security protections and facilitation of consumer rights. See “A Roadmap to Understanding and Complying With the California Consumer Privacy Act” (Nov. 14, 2019). In addition to summarizing the upcoming filing requirements and code of ethics reporting deadlines, this eleventh 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 (ACA), provides important points hedge fund managers should consider to ensure a smooth process for completing the annual updating amendments to Form ADV, as well as an assortment of annual compliance-related matters. It also discusses considerations for the upcoming Form CRS filing; proposed changes to the accredited investor definition and the advertising and cash solicitation rules; and 2020 exam priorities for the Office of Compliance Inspections and Examinations. For more from ACA, see “2019’s Key Compliance Trends and Issues” (Jan. 9, 2020).

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