Published on Oct 1st, 2020 |

In this issue of Vigilant’s Compliance Recap, we have highlighted some important takeaways from the month of September and some reminders for the upcoming months.

New Rules, Regulations, and Guidance

  • SEC Adopted Amendments to Modernize Shareholder Proposal Rule
    • Useful for: Shareholders, Investors, Market Participants, Funds, and Fund Advisers
  • SEC Adopts Amendments to Enhance Retail Investor Protections and Modernize the Rule Governing Quotations for Over-the-Counter Securities
    • Useful for: Retail Investors, Broker/Dealers 
  • SEC Adds Clarity, Efficiency and Transparency to Its Successful Whistleblower Award Program
    • Useful for: All


Upcoming Filings 

  • Form 13H Quarterly Filing for Changes- October 9, 2020

    • Form 13H (large trader) quarterly filing is due for the calendar quarter end Q3 2020 for advisers that already have a Form 13H filing obligation and have changes to any of the information reported.
  • Form PF for Large Liquidity Fund Advisers- October 15, 2020
    • Large liquidity fund advisers must file Form PF with the SEC on the IARD system within 15 days of each fiscal quarter end.  (This due date assumes a fiscal year end of December 31st and may need to be adjusted according to your firm’s fiscal year end.)
  • Form 13F- November 13, 2020
    • 13F quarterly filing is due for Q3 2020 within 45 days after the end of the calendar quarter.



  • In response to the OCIE Risk Alert for “Credential Stuffing” attacks among RIAs and BDs, the experts at Vigilant have created a Risk Mitigation Checklist.
  • Top 5 Reasons Vigilant Can provide YOU Value:
    • Check out our LinkedIn post here to learn more!


The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!

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