With many hedge fund compliance teams still operating remotely, the typical first quarter annual compliance planning, review and update processes may have increased significance in light of business changes many hedge fund managers experienced during the coronavirus pandemic. More specifically, for many fund managers, the first quarter of the new year is often a time to update Form ADV; finalize and deliver an updated compliance manual to employees; and collect employees’ annual disclosures and personal holdings reports. This fifteenth installment of the Hedge Fund Law Report’s quarterly compliance update, authored by consultants Joey Martinez and Chris Ray of ACA Compliance Group (ACA), highlights various important points for fund managers to consider to help ensure a smooth process for completing the annual updating amendments to Form ADV. In addition, this article summarizes certain filings required of fund managers that are due in the first quarter, as well as code of ethics reporting deadlines; various risk alerts issued by the recently renamed Division of Examinations – formerly the Office of Compliance Inspections and Examinations, or OCIE; a regulatory reminder on CCO authority and empowerment; updates on European and U.K. short selling reporting requirements; and some annual compliance-related items that many fund managers consider during the first quarter of the year. For more from ACA, see “Advisers Must Prepare for the Upcoming Expansion of the E.U. and U.K. Prudential Regimes
” (Nov. 12, 2020); and “Advisers Should Be Planning Now for the End of LIBOR
” (Oct. 29, 2020).