Amid coronavirus’ growing impact on both the health of citizens and institutions around the globe, authoritative organizations everywhere have taken action to help ease some of the burdens that are coinciding with nationwide lockdowns, closures of non-essential businesses, and more. In an effort to mitigate the potential ramifications of the virus on financial market participants, the SEC has announced this month that it will be extending filing deadlines for a number of regulatory obligations including Form ADV, Form PF, and Brochure Delivery.
As part of this relief initiative, investment advisers and funds will be granted a 45-day extension, which became effective on filings and delivery requirements due from the date of the announcement on March 13th to April 30th, 2020. According to law firm Proskauer, this order will specifically affect the following obligations under the Investment Advisers Act:
- Amendments to Form ADV. Registered advisers and exempt reporting advisers (ERAs) with fiscal years ending December 31 have annual updating amendments due on March 30, 2020
- Form PF Filings. Registered advisers to private funds with fiscal years ending December 31 that must file Form PF have filing deadlines of April 29, 2020
- Brochure Delivery. Registered advisers that must deliver to clients an updated brochure (Part 2A) or brochure supplement (Part 2B) have delivery obligations 120 days after the end of their fiscal year (, April 29, 2020, for advisers with fiscal years ending December 31)
Should a firm choose to take advantage of this granted extension, it must first take a number of steps in order to become eligible. These steps include making the claim that it will be relying on the order due to conditions resulting directly from the coronavirus outbreak along with a brief description of the reasons as to why it could not file on time and an estimated date that it projects to be able to between the defined March 13th to April 30th range.
With the assistance of IVP REGULATORY REPORTING (RAPTOR) and Raptor-as-a-Service, firms are powered by automation and a team of highly experienced regulatory analysts that work together to significantly reduce filing times and streamline the compliance process. As the threat of coronavirus continues to mount, Indus Valley Partners will continue to monitor the situation closely on a global scale to do its part in helping its clients, employees, and industry partners mitigate its potential lasting effects through its solutions, services, and a team of dedicated personnel.
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