| July | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Collect quarterly transaction reports | Personal Trading & Code of Ethics | Jul 30 | 2 weeks prior | |||
| Run a semiannual phishing simulation | Cybersecurity Program | Jul 30 | 2 weeks prior | |||
| Review custody & client-asset safeguards (quarterly) | Regulatory Reporting | Jul 31 | 2 weeks prior | |||
| Review portfolio-management performance & risk (quarterly) | Regulatory Reporting | Jul 31 | 2 weeks prior | |||
| Review employee political contributions (semiannual) | Personal Trading & Code of Ethics | Jul 31 | Begin early July | |||
| Monitor ERISA compliance (Fund) | Regulatory Reporting | Jul 31 | Ongoing | |||
| Review and reconcile fees & expenses (quarterly) | General Compliance Program | Jul 31 | 2 weeks prior | |||
| Review valuation & pricing methodology (quarterly) | General Compliance Program | Jul 31 | 2 weeks prior | |||
| Review and update restricted-security list (quarterly) | General Compliance Program | Jul 31 | Ongoing | |||
| Substantiate marketing-materials performance (quarterly) | Marketing & Advertising | Jul 31 | 2–3 weeks after Q2 close | |||
| August | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| File quarterly Form 13F | Regulatory Filings & Disclosures | Aug 14 | 3 weeks prior | |||
| Review employee personal-securities transactions (quarterly) | Personal Trading & Code of Ethics | Aug 15 | 1–2 weeks prior | |||
| Review investment allocations (semiannual) | General Compliance Program | Aug 31 | 2–3 weeks prior | |||
| Continue annual compliance-program review (mid-year check) | General Compliance Program | Aug 31 | 2 weeks prior | |||
| Review a sample of emails (quarterly) | Books & Recordkeeping | Aug 31 | 2 weeks prior | |||
| September | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Convene quarterly compliance/investment-committee meeting | General Compliance Program | Mid-Sep | 2 weeks prior | |||
| Review custody & client-asset safeguards (quarterly) | Regulatory Reporting | Sep 30 | 2 weeks prior | |||
| Review portfolio-management performance & risk (quarterly) | Regulatory Reporting | Sep 30 | 2 weeks prior | |||
| Review and reconcile fees & expenses (quarterly) | General Compliance Program | Sep 30 | 2 weeks prior | |||
| Review valuation & pricing methodology (quarterly) | General Compliance Program | Sep 30 | 2 weeks prior | |||
| October | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Review a sample of emails (quarterly) | Books & Recordkeeping | Oct 15 | 2 weeks prior | |||
| Collect quarterly transaction reports | Personal Trading & Code of Ethics | Oct 30 | 2 weeks prior | |||
| Collect annual social-media certifications & disclosures | Marketing & Advertising | Oct 31 | 2 weeks prior | |||
| Monitor ERISA compliance (Fund) | Regulatory Reporting | Oct 31 | Ongoing | |||
| Conduct annual compliance training | Compliance Training | Oct 31 | 2–3 weeks prior | |||
| Review marketing documents (annual) | Marketing & Advertising | Oct 31 | 2–3 weeks prior | |||
| Substantiate marketing-materials performance (quarterly) | Marketing & Advertising | Oct 31 | 2–3 weeks after Q3 close | |||
| Review and update restricted-security list (quarterly) | General Compliance Program | Oct 31 | Ongoing | |||
| November | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| File quarterly Form 13F | Regulatory Filings & Disclosures | Nov 14 | 3 weeks prior | |||
| Review employee personal-securities transactions (quarterly) | Personal Trading & Code of Ethics | Nov 15 | 1–2 weeks prior | |||
| Brief executives on cybersecurity (annual) | Cybersecurity Program | Mid-Nov | 2 weeks prior | |||
| Review fund documents (annual) | Regulatory Reporting | Nov 30 | 4 weeks prior | |||
| Review security-awareness training effectiveness (annual) | Cybersecurity Program | Nov 30 | 1–2 weeks prior | |||
| Complete annual compliance-program review | General Compliance Program | Nov 30 | 1–2 weeks prior | |||
| Run an annual mock SEC examination drill | General Compliance Program | Nov 30 | 4 weeks prior | |||
| December | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Pay IARD renewal fees | Regulatory Filings & Disclosures | early Dec — see current-year IARD bulletin | Begin mid-Nov (preliminary statement posts). | |||
| File state notice-filing annual renewals | Regulatory Filings & Disclosures | early Dec — see current-year IARD bulletin | 4 weeks prior | |||
| Convene quarterly compliance/investment-committee meeting | General Compliance Program | Mid-Dec | 2 weeks prior | |||
| Begin regulatory-filings & disclosures audit | Books & Recordkeeping | Dec 31 | Begin Nov 30 | |||
| Monitor third-party providers & business-continuity testing | Cybersecurity Program | Dec 31 | Begin Nov 30 | |||
| Review employee political contributions (semiannual) | Personal Trading & Code of Ethics | Dec 31 | 2 weeks prior | |||
| Review portfolio-management performance & risk (quarterly) | Regulatory Reporting | Dec 31 | 2 weeks prior | |||
| Run a semiannual phishing simulation | Cybersecurity Program | Dec 31 | 2 weeks prior | |||
| Audit books & records for compliance (annual) | Books & Recordkeeping | Dec 31 | 4 weeks prior | |||
| Review duty-to-supervise controls (annual) | General Compliance Program | Dec 31 | 4 weeks prior | |||
| Review overall compliance-program effectiveness (annual) | General Compliance Program | Dec 31 | 4 weeks prior | |||
| Analyze gaps against SEC exam risk alerts (annual) | General Compliance Program | Dec 31 | 4 weeks prior | |||
| Review consolidated conflicts of interest (annual) | General Compliance Program | Dec 31 | 4 weeks prior | |||
| Review and reconcile fees & expenses (quarterly) | General Compliance Program | Dec 31 | 2 weeks prior | |||
| Review valuation & pricing methodology (quarterly) | General Compliance Program | Dec 31 | 2 weeks prior | |||
| Re-screen investor base against OFAC (semiannual) | AML & Sanctions | Dec 31 | 2 weeks prior | |||
| January | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Test cybersecurity controls | Cybersecurity Program | Mid-Jan | 2 weeks prior | |||
| Collect quarterly transaction reports | Personal Trading & Code of Ethics | Jan 30 | 2 weeks prior | |||
| Collect annual compliance-manual & code-of-ethics acknowledgments | Personal Trading & Code of Ethics | Jan 31 | 2 weeks prior | |||
| Collect annual outside-business-activity disclosures | Personal Trading & Code of Ethics | Jan 31 | 2 weeks prior | |||
| Review and update restricted-security list (quarterly) | General Compliance Program | Jan 31 | 2 weeks prior | |||
| Monitor Rule 506(d) bad-actor covered persons | General Compliance Program | Jan 31 | Ongoing | |||
| Review investment allocations (semiannual) | General Compliance Program | Jan 31 | 2 weeks prior | |||
| Review a sample of emails (quarterly) | Books & Recordkeeping | Jan 31 | 2 weeks prior | |||
| Monitor ERISA compliance (Fund) | Regulatory Reporting | Jan 31 | Ongoing | |||
| Substantiate marketing-materials performance (quarterly) | Marketing & Advertising | Jan 31 | 2–3 weeks after Q4 close | |||
| February | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Collect access persons' annual holdings reports (current within 45 days of report date) | Personal Trading & Code of Ethics | Feb 14 | 3 weeks prior | |||
| File quarterly Form 13F | Regulatory Filings & Disclosures | Feb 14 | 3 weeks prior | |||
| Review employee personal-securities transactions (quarterly) | Personal Trading & Code of Ethics | Feb 15 | 1–2 weeks prior | |||
| Begin annual compliance-program review | General Compliance Program | Feb 28 | 2 weeks prior | |||
| Review custody & client-asset safeguards (quarterly) | Regulatory Reporting | Feb 28 | 2 weeks prior | |||
| March | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Review Form CRS for accuracy (annual) | Regulatory Filings & Disclosures | internal review cadence (no annual filing) | 2 weeks prior | |||
| Convene quarterly compliance/investment-committee meeting | General Compliance Program | Mid-Mar | 2 weeks prior | |||
| File Form ADV Part 1 annual amendment | Regulatory Filings & Disclosures | Mar 31 | Begin in January | |||
| File FATCA annual report (Form 8966) | Regulatory Filings & Disclosures | Mar 31 — IRS/CPA (conditional) | 6 weeks prior | |||
| Conduct annual security-risk assessment | Cybersecurity Program | Mar 31 | 2 weeks prior | |||
| Review custody & client-asset safeguards (quarterly) | Regulatory Reporting | Mar 31 | 2 weeks prior | |||
| Review portfolio-management performance & risk (quarterly) | Regulatory Reporting | Mar 31 | 2 weeks prior | |||
| Review and reconcile fees & expenses (quarterly) | General Compliance Program | Mar 31 | 2 weeks prior | |||
| Review valuation & pricing methodology (quarterly) | General Compliance Program | Mar 31 | 2 weeks prior | |||
| April | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Review a sample of emails (quarterly) | Books & Recordkeeping | Apr 15 | 2 weeks prior | |||
| Review and update restricted-security list (quarterly) | General Compliance Program | Apr 15 | Ongoing | |||
| Deliver Form ADV Part 2A & 2B to clients (annual) | Regulatory Filings & Disclosures | Apr 30 | 2–4 weeks prior | |||
| File Form PF annual filing | Regulatory Filings & Disclosures | Apr 30 | 4 weeks prior | |||
| Collect quarterly transaction reports | Personal Trading & Code of Ethics | Apr 30 | 2 weeks prior | |||
| Monitor ERISA compliance (Fund) | Regulatory Reporting | Apr 30 | Ongoing | |||
| Send annual privacy-policy notice to investors (only if the privacy policy changed in the past calendar year) | General Compliance Program | Apr 30 | Conditional (FAST Act) | |||
| Deliver audited financial statements to fund investors (annual) | Books & Recordkeeping | Apr 30 | Begin in Q1 | |||
| Review custody relationships (annual) | General Compliance Program | Apr 30 | 2 weeks prior | |||
| Substantiate marketing-materials performance (quarterly) | Marketing & Advertising | Apr 30 | 2–3 weeks after Q1 close | |||
| May | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Conduct annual security-awareness training | Cybersecurity Program | Mid-May | 2 weeks prior | |||
| Review disaster-recovery & business-continuity plan (annual) | General Compliance Program | May 14 | 2–3 weeks prior | |||
| Review Reg S-P incident-response program (annual) | Books & Recordkeeping | May 14 | 2 weeks prior | |||
| Check Regulation S-P privacy compliance (annual) | General Compliance Program | May 14 | 2 weeks prior | |||
| Review employee personal-securities transactions (quarterly) | Personal Trading & Code of Ethics | May 15 | 1–2 weeks prior | |||
| File quarterly Form 13F | Regulatory Filings & Disclosures | May 15 | 3 weeks prior | |||
| Review policies & procedures (annual) | General Compliance Program | May 31 | 1–2 weeks prior | |||
| Review service-provider / vendor oversight (annual) | General Compliance Program | May 31 | 6 weeks prior | |||
| Review whistleblower program (annual) | Books & Recordkeeping | May 31 | 2 weeks prior | |||
| June | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Convene quarterly compliance/investment-committee meeting | General Compliance Program | Mid-Jun | 2 weeks prior | |||
| Review best execution (annual) | Regulatory Reporting | Jun 30 | 4 weeks prior | |||
| Re-screen investor base against OFAC (semiannual) | AML & Sanctions | Jun 30 | 2 weeks prior | |||
| July | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Collect quarterly transaction reports | Personal Trading & Code of Ethics | Jul 30 | 2 weeks prior | |||
| Run a semiannual phishing simulation | Cybersecurity Program | Jul 30 | 2 weeks prior | |||
| Review custody & client-asset safeguards (quarterly) | Regulatory Reporting | Jul 31 | 2 weeks prior | |||
| Review portfolio-management performance & risk (quarterly) | Regulatory Reporting | Jul 31 | 2 weeks prior | |||
| Review employee political contributions (semiannual) | Personal Trading & Code of Ethics | Jul 31 | Begin early July | |||
| Monitor ERISA compliance (Fund) | Regulatory Reporting | Jul 31 | Ongoing | |||
| Review and reconcile fees & expenses (quarterly) | General Compliance Program | Jul 31 | 2 weeks prior | |||
| Review valuation & pricing methodology (quarterly) | General Compliance Program | Jul 31 | 2 weeks prior | |||
| Review and update restricted-security list (quarterly) | General Compliance Program | Jul 31 | Ongoing | |||
| Substantiate marketing-materials performance (quarterly) | Marketing & Advertising | Jul 31 | 2–3 weeks after Q2 close | |||
| August | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| File quarterly Form 13F | Regulatory Filings & Disclosures | Aug 14 | 3 weeks prior | |||
| Review employee personal-securities transactions (quarterly) | Personal Trading & Code of Ethics | Aug 15 | 1–2 weeks prior | |||
| Review investment allocations (semiannual) | General Compliance Program | Aug 31 | 2–3 weeks prior | |||
| Continue annual compliance-program review (mid-year check) | General Compliance Program | Aug 31 | 2 weeks prior | |||
| Review a sample of emails (quarterly) | Books & Recordkeeping | Aug 31 | 2 weeks prior | |||
| September | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Convene quarterly compliance/investment-committee meeting | General Compliance Program | Mid-Sep | 2 weeks prior | |||
| Review custody & client-asset safeguards (quarterly) | Regulatory Reporting | Sep 30 | 2 weeks prior | |||
| Review portfolio-management performance & risk (quarterly) | Regulatory Reporting | Sep 30 | 2 weeks prior | |||
| Review and reconcile fees & expenses (quarterly) | General Compliance Program | Sep 30 | 2 weeks prior | |||
| Review valuation & pricing methodology (quarterly) | General Compliance Program | Sep 30 | 2 weeks prior | |||
| October | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Review a sample of emails (quarterly) | Books & Recordkeeping | Oct 15 | 2 weeks prior | |||
| Collect quarterly transaction reports | Personal Trading & Code of Ethics | Oct 30 | 2 weeks prior | |||
| Collect annual social-media certifications & disclosures | Marketing & Advertising | Oct 31 | 2 weeks prior | |||
| Monitor ERISA compliance (Fund) | Regulatory Reporting | Oct 31 | Ongoing | |||
| Conduct annual compliance training | Compliance Training | Oct 31 | 2–3 weeks prior | |||
| Review marketing documents (annual) | Marketing & Advertising | Oct 31 | 2–3 weeks prior | |||
| Substantiate marketing-materials performance (quarterly) | Marketing & Advertising | Oct 31 | 2–3 weeks after Q3 close | |||
| Review and update restricted-security list (quarterly) | General Compliance Program | Oct 31 | Ongoing | |||
| November | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| File quarterly Form 13F | Regulatory Filings & Disclosures | Nov 14 | 3 weeks prior | |||
| Review employee personal-securities transactions (quarterly) | Personal Trading & Code of Ethics | Nov 15 | 1–2 weeks prior | |||
| Brief executives on cybersecurity (annual) | Cybersecurity Program | Mid-Nov | 2 weeks prior | |||
| Review fund documents (annual) | Regulatory Reporting | Nov 30 | 4 weeks prior | |||
| Review security-awareness training effectiveness (annual) | Cybersecurity Program | Nov 30 | 1–2 weeks prior | |||
| Complete annual compliance-program review | General Compliance Program | Nov 30 | 1–2 weeks prior | |||
| Run an annual mock SEC examination drill | General Compliance Program | Nov 30 | 4 weeks prior | |||
| December | Category | Due | Lead Time | Owner | Start | Done |
| Convene monthly cybersecurity meeting | Cybersecurity Program | Monthly | Firm-scheduled | |||
| Pay IARD renewal fees | Regulatory Filings & Disclosures | early Dec — see current-year IARD bulletin | Begin mid-Nov (preliminary statement posts). | |||
| File state notice-filing annual renewals | Regulatory Filings & Disclosures | early Dec — see current-year IARD bulletin | 4 weeks prior | |||
| Convene quarterly compliance/investment-committee meeting | General Compliance Program | Mid-Dec | 2 weeks prior | |||
| Begin regulatory-filings & disclosures audit | Books & Recordkeeping | Dec 31 | Begin Nov 30 | |||
| Monitor third-party providers & business-continuity testing | Cybersecurity Program | Dec 31 | Begin Nov 30 | |||
| Review employee political contributions (semiannual) | Personal Trading & Code of Ethics | Dec 31 | 2 weeks prior | |||
| Review portfolio-management performance & risk (quarterly) | Regulatory Reporting | Dec 31 | 2 weeks prior | |||
| Run a semiannual phishing simulation | Cybersecurity Program | Dec 31 | 2 weeks prior | |||
| Audit books & records for compliance (annual) | Books & Recordkeeping | Dec 31 | 4 weeks prior | |||
| Review duty-to-supervise controls (annual) | General Compliance Program | Dec 31 | 4 weeks prior | |||
| Review overall compliance-program effectiveness (annual) | General Compliance Program | Dec 31 | 4 weeks prior | |||
| Analyze gaps against SEC exam risk alerts (annual) | General Compliance Program | Dec 31 | 4 weeks prior | |||
| Review consolidated conflicts of interest (annual) | General Compliance Program | Dec 31 | 4 weeks prior | |||
| Review and reconcile fees & expenses (quarterly) | General Compliance Program | Dec 31 | 2 weeks prior | |||
| Review valuation & pricing methodology (quarterly) | General Compliance Program | Dec 31 | 2 weeks prior | |||
| Re-screen investor base against OFAC (semiannual) | AML & Sanctions | Dec 31 | 2 weeks prior | |||
| Obligation | Category | Trigger | Timing | Owner | Start | Done |
|---|---|---|---|---|---|---|
| File Schedule 13G amendment | Regulatory Filings & Disclosures | 45d after quarter of material change | 2 weeks prior | |||
| File Form PF quarterly filing (Large HF Advisers) | Regulatory Filings & Disclosures | Each quarter-end | Within 60 days | |||
| Review AML/CFT program (annual) | Books & Recordkeeping | Not yet effective — Jan 1 2028 (FinCEN IA AML Rule) | Ongoing | |||
| File CRS reports with foreign tax authorities (annual) | Regulatory Filings & Disclosures | varies by jurisdiction | Coordinate with fund admin | |||
| Review AML/CFT program effectiveness | Books & Recordkeeping | Not yet effective — Jan 1 2028 (FinCEN IA AML Rule) | Begin Nov 30 | |||
| Deliver Form ADV Part 2A & 2B to new clients | Regulatory Filings & Disclosures | New client | At / before engagement | |||
| File Form D amendment | Regulatory Filings & Disclosures | Material change | Annually / as soon as practicable | |||
| File Blue Sky notices / updates | Regulatory Filings & Disclosures | New offering | Varies by state — many within 15 days of first sale in the state. | |||
| File initial Form D (new offering) | Regulatory Filings & Disclosures | New offering | Within 15 days of first sale | |||
| Deliver initial compliance training to new employees | Compliance Training | New hire | Immediately upon hire | |||
| Collect initial holdings, OBA & political-contribution disclosures | Personal Trading & Code of Ethics | New hire | Within 10 days of hire | |||
| Monitor benefit-plan investor ownership (ERISA 25% test) | Regulatory Reporting | Subscription / transfer | At each subscription or transfer. | |||
| Review and pre-approve social-media activity | Marketing & Advertising | Any post | Before publication | |||
| Pre-clear employee political contributions | Personal Trading & Code of Ethics | Any contribution | Upon contribution | |||
| Review new-investor subscription documents | Personal Trading & Code of Ethics | New subscription | Upon receipt | |||
| Perform initial due diligence on a new third-party vendor | General Compliance Program | New vendor | Prior to engagement | |||
| Review and respond to investor complaints | General Compliance Program | Any complaint | Immediately | |||
| Review proxy voting | General Compliance Program | Corporate vote | Per vote schedule | |||
| Review side letters / customized agreements | Regulatory Reporting | New agreement | At execution | |||
| Process new-investor remittance forms | Regulatory Reporting | New subscription | Upon receipt | |||
| File a prompt ADV Part 2A update (material change) | Regulatory Filings & Disclosures | Material change | Promptly upon change | |||
| Deliver Form CRS to new retail clients | Regulatory Filings & Disclosures | New relationship | At / before engagement | |||
| File a prompt Form CRS amendment (material change) | Regulatory Filings & Disclosures | Material change | Within 60 days | |||
| File initial Schedule 13D | Regulatory Filings & Disclosures | Cross >5% beneficial ownership | Within 5 business days | |||
| File a Suspicious Activity Report (SAR) | AML & Sanctions | Not yet effective — Jan 1 2028 (FinCEN IA AML Rule) | Within 30 days | |||
| File Form PF current report (Large Hedge Fund Advisers) | Regulatory Reporting | Triggering event | ASAP, ≤72 hrs | |||
| File Form PF Section 6 event report (PE Fund Advisers) | Regulatory Reporting | Qualifying event | 60 days after quarter-end | |||
| Pre-clear and monitor gifts & entertainment | Personal Trading & Code of Ethics | Any gift or entertainment event | Ongoing — before event | |||
| File ADV updates & notifications for key-personnel changes | Regulatory Filings & Disclosures | Key personnel change | Promptly upon change | |||
| Review registration & filing on an AUM-threshold crossing | Regulatory Filings & Disclosures | AUM threshold crossed in either direction | Upon crossing; assess within current quarter reporting cycle | |||
| Update filings & BCP on a significant office relocation | Regulatory Filings & Disclosures | Office relocation | ADV promptly upon change; BCP before occupancy |