Published: 13th January 2016

Now that 2016 is firmly upon us, a number of United States regulatory filing deadlines come into view, particularly for firms with a 31 December fiscal year end (“FYE”). The chart below lists important filing requirements and corresponding 2016 filing deadlines. A pdf version is available here.

To find out more information about year end United States filing requirements and their applicability contact Complyport’s International Desk at +44 (0)20 7399 4980 or info@complyport.co.uk.

Filing/Requirement Ongoing Deadlines 2016 Date (FYE December 31) Notes
Form ADV Parts 1 and 2A Annual Updates Parts 1 and 2A annual updates must be filed within 90 days of adviser’s fiscal year end electronically on IARD Wednesday, 30 March 2016 Exempt Reporting Advisers only need to file Part 1 of Form ADV
Form PF Updates
Large Hedge Fund Advisers and Large Liquidity Advisers must update quarterly
All other advisers must updated annually
Part 1: Must update annually within 120 days of FYE
Part 2: Must update quarterly within 60 days of the end of each fiscal quarter
Part 3: Must update quarterly within 15 days of the end of each fiscal quarter
Part 4: must update annually within 120 days of FYE
Friday, 29 April 2016
Monday, 29 February 2016
15 January, 15 April, 15 July, 15 October
Friday, 29 April 2016
Form D Update Federal Form D – Annually if making a continuing offering in reliance on Regulation D on each anniversary of the date of initial filing Depends on initial filing date
Must update promptly following any material change to the Form D
State “blue sky” filings – Form D may need to be filed at the state level following admission of new US investors
Schedule 13D No annual update required Not applicable Material changes (+/- 1%) must be filed promptly (typically 1 business day)
Schedule 13G Annual update due 45 days after calendar year end Monday, February 15 2016 (14 February = Sunday)
Schedule 13F
Initial filing update required within 45 days of the end of each calendar year in which investor exceeds the $100 million threshold
Quarterly filing updates required within 45 days of the end of each calendar quarter once threshold is crossed
Monday, February 15 2016 (14 February = Sunday)
15 May 2016; 14 August 2016; 14 November 2016
Schedule 13H
“Large Trader Reporting”
Annual updates must be filed 45 days after calendar year end Monday, February 15 2016 (14 February = Sunday) If the trader did not conduct aggregate transactions during the prior full calendar year that crossed the thresholds, it can file for “inactive status”
CFTC/NFA Registration Update Annually by the firm’s CFTC/NFA registration anniversary date with the NFA Depends on CFTC/NFA registration anniversary date (which can be checked on NFA BASIC)
NFA Questionnaire Annually within 12 months of the firm’s last self-examination Depends on firm’s last self-examination date
Form CPO-PQR & NFA-PQR
Quarterly with the NFA within 90 days of the calendar year end
Large CPOs (more than $1.5 billion AUM) within 60 days of the end of the three subsequent calendar quarters
Wednesday, 30 March 2016
Monday, 29 February 2016
Form CTA-PR & NFA PR Quarterly with the NFA within 45 days of the end of each calendar quarter
CFTC Exemption Renewals Annually within 60 days after each calendar year end Monday, 29 February 2016
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