Published on Nov 3rd, 2020 |

Hello November! In this issue of Vigilant’s Compliance Recap, we have highlighted some important takeaways from the month of October and some reminders for the end of the year! (2021 here we come!)

New Rules, Regulations, and Guidance

  • 10/7/2020: Regulatory Framework For Fund of Funds Arrangements is Updated by the SEC
    • On October 7th, the Securities and Exchange Commission voted to adopt a new rule and related amendments to facilitate a comprehensive regulatory framework for fund of funds arrangements. Click HERE to learn more
  • 10/7/2020: SEC Proposed Exemption From Broker-Dealer Registration for Finders 
    • On October 7th, the SEC released a public statement stating that the Commission has proposed to create a new exemption that will permit individuals to engage in traditional brokerage activity without the important investor protections that come with registration as a broker-dealer. Click HERE to learn more


  • Vigilant’s Client IM Global Rings the Bell at the NYSE, October 19, 2020
  • See upcoming SEC Meetings, including the Asset Management Advisory Committee Meeting, here.

Upcoming Filings 

  • Form 13F- November 13, 2020
    • 13F quarterly filing is due for Q3 2020 within 45 days after the end of the calendar quarter.
  • CTA Form PR Form- November 13, 2020
    • PR is required to be filed by CTAs quarterly with the NFA within 45 days following each calendar quarter-end.
  • Form PF for Large Hedge Fund Advisers- November 29, 2020
    • Large hedge fund advisers must file Form PF with the SEC on the IARD system within 60 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.) The due date falls on a Sunday in 2020, so we recommend filing the Friday prior.
  • CPO-PQR Form- November 29, 2020
    • Commodity Pool Operator Form CPO-PQR is required to be filed with the NFA for Commodity Pool Operators within 60 days of calendar quarter end. The Due date falls on a Sunday in 2020, so we recommend filing the Friday prior.
  • Resources
    • Outsourcing your CCO Vs Compliance Support
      • Trying to distinguish what the differences are between Outsourcing your CCO and Compliance Support? Click HERE to see Vigilant’s Insights!
    • 5 Common Misconceptions in Compliance
      • The Compliance industry deals with lots of misconception… click HERE to see the top 5 misconceptions in Compliance!

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

The Team at Vigilant