| January | Category | Due | Lead Time | Owner | Start | Done |
| Annual Compliance Manual & Code of Ethics Acknowledgement | Employee Reporting | Jan 31 | 2 weeks prior | |||
| Annual Holdings Report (Access Persons — Rule 204A-1, within 45 days of calendar year-end) | Employee Reporting | Feb 14 | 3 weeks prior | |||
| Annual Outside Business Activities Disclosure Statement | Employee Reporting | Jan 31 | 2 weeks prior | |||
| Quarterly Transaction Reports — Q4 (Rule 204A-1, within 30 days of quarter-end) | Employee Reporting | Jan 30 | 2 weeks prior | |||
| Cybersecurity Controls Test | Cybersecurity | Jan 22 | 2 weeks prior | |||
| Restricted Security List — Review and Update | General Compliance | Jan 31 | 2 weeks prior | |||
| Rule 506(d) / Bad Actor Covered Person Monitoring | General Compliance | Jan 31 | Ongoing | |||
| Investment Allocations Review (Semi-Annual) | General Compliance | Jan 31 | 2 weeks prior | |||
| Email Reviews — Q4 Sampling (Rule 206(4)-7) | General Compliance | Jan 31 | 2 weeks prior | |||
| ERISA Monitoring — Q4(Fund) (DOL 25% Benefit Plan Investor Threshold; applies if benefit plan investors) | Fund Compliance | Jan 31 | Ongoing | |||
| Marketing Materials Performance Substantiation — Q4 (Rule 206(4)-1; update distributed materials to Q4 performance; verify substantiation records exist at time of distribution) | Regulatory Filings | Jan 31 | 2–3 weeks after Q4 close | |||
| February | Category | Due | Lead Time | Owner | Start | Done |
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Review Employee Personal Securities Transactions — Q4 | Employee Reporting | Feb 15 | 1–2 weeks prior | |||
| Annual Rule 206(4)-7 Compliance Review — Q1 Kickoff | General Compliance | Feb 28 | 2 weeks prior | |||
| Custody and Client Assets Safeguard Review — Q4 | Custody / Safeguarding | Feb 28 | 2 weeks prior | |||
| Form 13F Q4 Filing — Section 13(F) (managers with $100M+ in 13(F) securities; filed via EDGAR) | Regulatory Filings | Feb 14 | 3 weeks prior | |||
| Schedule 13G Annual Amendment (beneficial ownership ≥5% as passive investor; within 45 days of calendar year-end) | Regulatory Filings | Feb 14 | 2 weeks prior | |||
| Form PF Q4 Quarterly Filing — Large Hedge Fund Advisers(HF) (AUM ≥$1.5B; within 60 days of fiscal quarter-end; Mar 1 in standard years, Feb 28 in leap years) | Regulatory Filings | Mar 1 | Coordinate with deadline | |||
| March | Category | Due | Lead Time | Owner | Start | Done |
| Form ADV Part 1 Annual Amendment (within 90 days of fiscal year-end) | Regulatory Filings | Mar 31 | Begin in January | |||
| FATCA Annual Reporting — Form 8966(Fund) (participating FFIs, QIs, Model 2 FFIs, and U.S. withholding agents; Model 1 IGA jurisdictions report to local tax authority, not IRS directly; CRS reporting to applicable foreign tax authorities is separate — coordinate with fund administrator) | Regulatory Filings | Mar 31 | 6 weeks prior | |||
| Annual Security Risk Assessment (technical, procedural, policy) | Cybersecurity | Mar 31 | 2 weeks prior | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Custody and Client Assets Safeguard Review — Q1 | Custody / Safeguarding | Mar 31 | 2 weeks prior | |||
| Portfolio Management Performance & Risk Review — Q1 | Portfolio Management | Mar 31 | 2 weeks prior | |||
| Fees & Expenses Review and Reconciliation — Q1 | General Compliance | Mar 31 | 2 weeks prior | |||
| Valuation and Pricing Methodology Review — Q1 | General Compliance | Mar 31 | 2 weeks prior | |||
| Form CRS Annual Review and Currency Check(Retail) (retail-facing RIAs; confirm services, fees, conflicts, and disciplinary history remain accurate; review before ADV Part 1 annual amendment is filed) | Regulatory Filings | Mar 31 | 2 weeks prior | |||
| Compliance / Investment Committee Meeting — Q1 | Committee Meeting | Mid-Mar | 2 weeks prior | |||
| April | Category | Due | Lead Time | Owner | Start | Done |
| Form ADV Part 2A & 2B Periodic Delivery to Clients (within 120 days of fiscal year-end; includes supervisor brochure supplements for supervised persons with direct client contact) | Regulatory Filings | Apr 30 | 2–4 weeks prior | |||
| Form PF Annual Filing — All Filers(HF)(PE) (120 days of fiscal year-end; applies to large PE advisers ≥$2B PE AUM and advisers below the large HF adviser threshold; large PE advisers file expanded Section 4) | Regulatory Filings | Apr 30 | 4 weeks prior | |||
| Quarterly Transaction Reports — Q1 (Rule 204A-1, within 30 days of quarter-end) | Employee Reporting | Apr 30 | 2 weeks prior | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| ERISA Monitoring — Q1(Fund) (DOL 25% Benefit Plan Investor Threshold; applies if benefit plan investors) | Fund Compliance | Apr 30 | Ongoing | |||
| Annual Privacy Policy Notice to Investors (Regulation S-P §248.5; note: FAST Act exception — firms sharing data only within GLBA-enumerated exceptions that have not changed their policies may not be required to send the annual notice; confirm applicability annually) | General Compliance | Apr 30 | 2 weeks prior | |||
| Delivery of Audited Financial Statements to Fund Investors(Fund) (Custody Rule audit provision) | General Compliance | Apr 30 | Begin in Q1 | |||
| Email Reviews — Semi-Annual Q1 Sampling (Rule 206(4)-7) | General Compliance | Apr 15 | 2 weeks prior | |||
| Annual Custody Relationship Review (Custody Rule compliance) | General Compliance | Apr 30 | 2 weeks prior | |||
| Restricted Security List — Q1 Review and Update | General Compliance | Apr 15 | Ongoing | |||
| Marketing Materials Performance Substantiation — Q1 (Rule 206(4)-1; update distributed materials to Q1 performance; verify substantiation records exist at time of distribution) | Regulatory Filings | Apr 30 | 2–3 weeks after Q1 close | |||
| May | Category | Due | Lead Time | Owner | Start | Done |
| Review Employee Personal Securities Transactions — Q1 (Rule 204A-1) | Employee Reporting | May 15 | 1–2 weeks prior | |||
| Annual Policies & Procedures Review (currency, accuracy, coverage gaps) | General Compliance | May 31 | 1–2 weeks prior | |||
| Disaster Recovery & Business Continuity Plan — Annual Review and Test | General Compliance | May 14 | 2–3 weeks prior | |||
| Annual Service Provider / Vendor Oversight Review | General Compliance | May 31 | 6 weeks prior | |||
| Reg S-P Incident Response Program Annual Review (2024 amendments — written incident response policies; breach notification procedures (30-day notification requirement); service provider contract review for Customer Information protections; recordkeeping documentation; RIAs ≥$1.5B AUM: in effect December 3, 2025; smaller entities: June 3, 2026) | General Compliance | May 14 | 2 weeks prior | |||
| Regulation S-P Privacy Compliance Annual Check (privacy notice delivery, opt-out procedures, Safeguards Rule) | General Compliance | May 14 | 2 weeks prior | |||
| AML/CFT Program Review — Annual CCO Assessment (FinCEN/SEC final rule 2024: mandatory federal obligation for covered investment advisers effective January 1, 2026; written AML/CFT program, customer identification procedures, ongoing monitoring, recordkeeping) | AML | Rolling | Ongoing | |||
| Security Awareness Training — Annual Employee Program | Cybersecurity | May 11 | 2 weeks prior | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Form 13F Q1 Filing — Section 13(F) (managers with $100M+ in 13(F) securities) | Regulatory Filings | May 15 | 3 weeks prior | |||
| Whistleblower Program Annual Review — Rule 21F-17 (audit separation agreements, NDAs, and confidentiality policies for SEC-reporting deterrence; confirm internal channel operational; issue annual staff reminder) | General Compliance | May 31 | 2 weeks prior | |||
| June | Category | Due | Lead Time | Owner | Start | Done |
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Best Execution Annual Review — Section 28(e) (soft dollar and client commission arrangement evaluation; written report documenting broker evaluation criteria) | Portfolio Management | Jun 30 | 4 weeks prior | |||
| OFAC Investor Base Re-screening — Semi-Annual (full re-screen of existing investor roster against current SDN and blocked persons list; document results) | AML | Jun 30 | 2 weeks prior | |||
| CRS Reporting to Foreign Tax Authorities — Non-U.S. Fund Vehicles(Fund) (jurisdiction-specific deadlines; coordinate with fund administrator; timing varies by IGA jurisdiction) | Regulatory Filings | Rolling | Coordinate with fund admin | |||
| Compliance / Investment Committee Meeting — Q2 | Committee Meeting | Mid-Jun | 2 weeks prior | |||
| July | Category | Due | Lead Time | Owner | Start | Done |
| Custody and Client Assets Safeguard Review — Q2 | Custody / Safeguarding | Jul 31 | 2 weeks prior | |||
| Portfolio Management Performance & Risk Review — Q2 | Portfolio Management | Jul 31 | 2 weeks prior | |||
| Quarterly Transaction Reports — Q2 (Rule 204A-1, within 30 days of quarter-end) | Employee Reporting | Jul 30 | 2 weeks prior | |||
| Review of Employee Political Contributions — Semi-Annual (SEC Rule 206(4)-5) | Employee Reporting | Jul 31 | Begin early July | |||
| ERISA Monitoring — Q2(Fund) (DOL 25% Benefit Plan Investor Threshold; applies if benefit plan investors) | Fund Compliance | Jul 31 | Ongoing | |||
| Fees & Expenses Review and Reconciliation — Q2 | General Compliance | Jul 31 | 2 weeks prior | |||
| Valuation and Pricing Methodology Review — Q2 | General Compliance | Jul 31 | 2 weeks prior | |||
| Restricted Security List — Q2 Review and Update | General Compliance | Jul 31 | Ongoing | |||
| Marketing Materials Performance Substantiation — Q2 (Rule 206(4)-1; update distributed materials to Q2 performance; verify substantiation records exist at time of distribution) | Regulatory Filings | Jul 31 | 2–3 weeks after Q2 close | |||
| Phishing Simulation — Semi-Annual (behavioral vulnerability assessment) | Cybersecurity | Jul 30 | 2 weeks prior | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| August | Category | Due | Lead Time | Owner | Start | Done |
| Review Employee Personal Securities Transactions — Q2 (Rule 204A-1) | Employee Reporting | Aug 15 | 1–2 weeks prior | |||
| Investment Allocations Review — Semi-Annual (fair allocation among clients/funds) | Employee Reporting | Aug 31 | 2–3 weeks prior | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Annual Rule 206(4)-7 Compliance Review — Quarterly Progress Check | General Compliance | Aug 31 | 2 weeks prior | |||
| Email Reviews — Q2 Sampling (Rule 206(4)-7) | General Compliance | Aug 31 | 2 weeks prior | |||
| Form 13F Q2 Filing — Section 13(F) (managers with $100M+ in 13(F) securities) | Regulatory Filings | Aug 14 | 3 weeks prior | |||
| September | Category | Due | Lead Time | Owner | Start | Done |
| Custody and Client Assets Safeguard Review — Q3 | Custody / Safeguarding | Sep 30 | 2 weeks prior | |||
| Portfolio Management Performance & Risk Review — Q3 | Portfolio Management | Sep 30 | 2 weeks prior | |||
| Compliance / Investment Committee Meeting — Q3 | Committee Meeting | Mid-Sep | 2 weeks prior | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Fees & Expenses Review and Reconciliation — Q3 | General Compliance | Sep 30 | 2 weeks prior | |||
| Valuation and Pricing Methodology Review — Q3 | General Compliance | Sep 30 | 2 weeks prior | |||
| October | Category | Due | Lead Time | Owner | Start | Done |
| Annual Social Media Certification and Disclosure (all employees) | Employee Reporting | Oct 31 | 2 weeks prior | |||
| Quarterly Transaction Reports — Q3 (Rule 204A-1, within 30 days of quarter-end) | Employee Reporting | Oct 30 | 2 weeks prior | |||
| ERISA Monitoring — Q3(Fund) (DOL 25% Benefit Plan Investor Threshold; applies if benefit plan investors) | Fund Compliance | Oct 31 | Ongoing | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Annual Compliance Training (Advisers Act topics, documented completion) | General Compliance | Oct 31 | 2–3 weeks prior | |||
| Marketing Documents Review — Annual (Rule 206(4)-1, Advertising Rule) | General Compliance | Oct 31 | 2–3 weeks prior | |||
| Marketing Materials Performance Substantiation — Q3 (Rule 206(4)-1; update distributed materials to Q3 performance; verify substantiation records exist at time of distribution) | Regulatory Filings | Oct 31 | 2–3 weeks after Q3 close | |||
| Email Reviews — Semi-Annual Q3 Sampling (Rule 206(4)-7) | General Compliance | Oct 15 | 2 weeks prior | |||
| Restricted Security List — Q3 Review and Update | General Compliance | Oct 31 | Ongoing | |||
| November | Category | Due | Lead Time | Owner | Start | Done |
| Review Employee Personal Securities Transactions — Q3 (Rule 204A-1) | Employee Reporting | Nov 15 | 1–2 weeks prior | |||
| Annual Fund Document Review(Fund) (LPA, PPM, subscription docs — currency and consistency) | Fund Compliance | Nov 30 | 4 weeks prior | |||
| Regulatory Filings and Disclosures Audit — Begin (ADV, Form PF, blue sky, Form D accuracy) | Regulatory Filings | Dec 31 | Begin Nov 30 | |||
| Form 13F Q3 Filing — Section 13(F) (managers with $100M+ in 13(F) securities) | Regulatory Filings | Nov 14 | 3 weeks prior | |||
| AML/CFT Program Effectiveness Review — Begin (FinCEN/SEC 2024 mandatory rule: annual assessment and control update; review AML/CFT program, CIP procedures, suspicious activity monitoring, and recordkeeping for BSA compliance) | AML | Dec 31 | Begin Nov 30 | |||
| Annual Executive Cybersecurity Briefing (12-month posture summary for senior leadership) | Cybersecurity | Nov 20 | 2 weeks prior | |||
| Security Awareness Training — Annual Effectiveness Review | Cybersecurity | Nov 30 | 1–2 weeks prior | |||
| Third-Party Provider Oversight and BCT Monitoring — Begin | Cybersecurity | Dec 31 | Begin Nov 30 | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Annual Rule 206(4)-7 Compliance Review — Final Progress Check | General Compliance | Nov 30 | 1–2 weeks prior | |||
| Annual Mock SEC Examination Drill (simulate examiner document request; test production readiness across standard first-day request categories; identify gaps before year-end) | General Compliance | Nov 30 | 4 weeks prior | |||
| December | Category | Due | Lead Time | Owner | Start | Done |
| IARD Renewal Statements — Pay Renewal Fees Prior to Year-End | Regulatory Filings | Dec 31 | Begin Dec 7 | |||
| Review of Employee Political Contributions — Semi-Annual (Rule 206(4)-5) | Employee Reporting | Dec 31 | 2 weeks prior | |||
| Portfolio Management Performance & Risk Review — Q4 | Portfolio Management | Dec 31 | 2 weeks prior | |||
| Phishing Simulation — Semi-Annual (behavioral vulnerability assessment) | Cybersecurity | Dec 31 | 2 weeks prior | |||
| Monthly Cybersecurity Meeting | Cybersecurity | Monthly | Firm-scheduled | |||
| Books & Records Audit and Compliance Review (Rule 204-2 retention) | General Compliance | Dec 31 | 4 weeks prior | |||
| Duty to Supervise — Annual Comprehensive Review | General Compliance | Dec 31 | 4 weeks prior | |||
| Comprehensive Compliance Program Effectiveness Review (integrate all sub-reviews) | General Compliance | Dec 31 | 4 weeks prior | |||
| EXAMS Risk Alert Annual Gap Analysis (review all SEC OCIE/EXAMS Risk Alerts issued in the year; assess gaps against current policies; document remediation decisions) | General Compliance | Dec 31 | 4 weeks prior | |||
| Consolidated Conflicts of Interest Review (aggregate all disclosures — employees, vendors, G&E, political) | General Compliance | Dec 31 | 4 weeks prior | |||
| Fees & Expenses Review and Reconciliation — Q4 | General Compliance | Dec 31 | 2 weeks prior | |||
| Valuation and Pricing Methodology Review — Q4 | General Compliance | Dec 31 | 2 weeks prior | |||
| OFAC Investor Base Re-screening — Semi-Annual (full re-screen of existing investor roster against current SDN and blocked persons list; document results) | AML | Dec 31 | 2 weeks prior | |||
| Compliance / Investment Committee Meeting — Q4 | Committee Meeting | Mid-Dec | 2 weeks prior | |||
| State Notice Filing Annual Renewals (states where RIA notice filings require annual renewal — confirm renewal deadlines with each state securities authority; varies by state) | Regulatory Filings | Dec 31 | 4 weeks prior | |||
| Obligation | Category | Trigger | Timing | Owner | Start | Done |
|---|---|---|---|---|---|---|
| ADV Part 2A & 2B Delivery to New Clients | Regulatory Filings | New client | At / before engagement | |||
| Form D Amendment Filing(Fund) (material changes to offering) | Regulatory Filings | Material change | Within 15 days | |||
| Blue Sky Notice Filings / Updates(Fund) (new investor states) | Regulatory Filings | New offering | Prior to first sale | |||
| Form D Initial Filing — New Offering(Fund) (first sale under Rule 506; within 15 days of first sale) | Regulatory Filings | New offering | Within 15 days of first sale | |||
| Initial Employee Compliance Training | Employee Reporting | New hire | Immediately upon hire | |||
| Initial Holdings, OBA & Political Contribution Disclosures (Rule 204A-1) | Employee Reporting | New hire | Within 10 days of hire | |||
| Benefit Plan Investment Disclosure (new hire ERISA/DOL threshold) | Employee Reporting | New hire | Immediately upon hire | |||
| Social Media Activity Review & Pre-Approval | Employee Reporting | Any post | Before publication | |||
| Employee Political Contribution Review (Rule 206(4)-5) | Employee Reporting | Any contribution | Upon contribution | |||
| New Investor Subscription Document Review(Fund) (LPA/PPM compliance, AML/KYC) | Employee Reporting | New subscription | Upon receipt | |||
| Initial Due Diligence — New Third-Party Vendor | General Compliance | New vendor | Prior to engagement | |||
| Investor Complaint Review and Response | General Compliance | Any complaint | Immediately | |||
| Proxy Voting Review (fiduciary compliance and policy adherence) | General Compliance | Corporate vote | Per vote schedule | |||
| Side Letter / Customized Agreement Review(Fund) | Fund Compliance | New agreement | At execution | |||
| New Investor Remittance Form Processing(Fund) | Fund Compliance | New subscription | Upon receipt | |||
| ADV Part 2A Prompt Update (material change outside annual cycle) | Regulatory Filings | Material change | Promptly upon change | |||
| Form CRS Delivery to New Retail Clients(Retail) | Regulatory Filings | New relationship | At / before engagement | |||
| Form CRS Prompt Amendment — Material Change(Retail) (within 30 days; deliver updated Form CRS to existing clients within 60 days) | Regulatory Filings | Material change | Within 30 days | |||
| Schedule 13D Initial Filing (beneficial ownership ≥5% with intent to influence; within 10 days of crossing threshold; prompt amendment on any material change) | Regulatory Filings | Threshold crossed | Within 10 days | |||
| Suspicious Activity Report (SAR) Filing (FinCEN/SEC 2024 mandatory rule: file within 30 days of detecting a transaction or pattern meeting BSA threshold; 60 days if no suspect can be identified; mandatory for covered investment advisers effective January 1, 2026) | AML | SAR threshold met | Within 30 days | |||
| Form PF Current Reporting — Large Hedge Fund Advisers(HF) (Section 5; qualifying funds NAV ≥$500M; triggering events: extraordinary investment losses ≥20% of NAV in any rolling 10-business-day period, margin/collateral increases ≥20%, margin default notice, significant operational disruption, redemption requests exceeding 50% of NAV net of subscriptions, or inability to satisfy redemptions) | Fund Compliance | Triggering event | Within 72 hours | |||
| Form PF Section 6 Event Reporting — PE Fund Advisers(PE) (all advisers with ≥$150M in PE AUM; triggering events: GP removal, fund termination, adviser-led secondary transactions, GP or LP clawbacks; file within 60 days of the quarter-end in which the event occurred) | Fund Compliance | Qualifying event | 60 days after quarter-end | |||
| Gifts & Entertainment Pre-clearance and Monitoring (Rule 204-2; pre-clear gifts above policy threshold before receipt or giving; log all G&E activity; review log for patterns no less than quarterly; flag anomalies to CCO) | Employee Reporting | Any gift or entertainment event | Ongoing — before event | |||
| Change in Key Personnel — ADV Update and Notifications (update ADV Part 1 Items 2.A and 5.F for principal officers and CCO; update or terminate Part 2B brochure supplement for affected supervised persons; update IARD profile; assess state-level notification requirements in applicable jurisdictions) | Regulatory Filings | Key personnel change | Promptly upon change | |||
| AUM Threshold Crossing — Registration and Filing Review ($100M: 13F reporting begins; $500M: Form PF annual filing threshold; $1.5B: large hedge fund adviser Form PF quarterly; $2B PE AUM: large PE adviser Form PF expanded Section 4; below $90M: mandatory switch from SEC to state registration, notify SEC within 180 days) | Regulatory Filings | AUM threshold crossed in either direction | Upon crossing; assess within current quarter reporting cycle | |||
| Significant Office Relocation — Filings and BCP Update (ADV Part 1 Item 1 principal office address; update state registration and notice filings for new jurisdiction; assess withdrawal requirements in prior jurisdiction; revise Business Continuity Plan for new physical location, recovery sites, and access procedures; update cybersecurity physical controls inventory) | Regulatory Filings | Office relocation | ADV promptly upon change; BCP before occupancy |