2017 Investment Adviser Compliance Calendar

2017 Investment Adviser Compliance Calendar

19100 Von Karman Ave., Suite 950 Irvine, California 92612 Tel +1 949 771 0344 Fax +1 949 608 3636 www.connexien.com

2017 Investment Adviser Compliance Calendar

Forward Dear Reader,

Our 2017 Investment Adviser Compliance Calendar update is intended to keep investment advisers informed of updated compliance reporting requirements and filing deadlines as well as provide information on market holidays and events that may affect investment adviser business operations.

This information is divided into two categories: compliance reporting and filing deadlines that are established on a calendar year basis and event-driven requirements that are set internally by investment advisory firms based on their previous year’s completion dates.

While this information is intended to be used as a reference guide when preparing and planning your annual investment adviser compliance program, we encourage each investment adviser firm to review its specific needs to determine the applicability of such requirements.

Although this information is primarily focused on SEC registered investment advisers, as federal and/or state investment adviser rules and regulations are subject to change, information on specific requirements as provided in this calendar should be verified to ensure compliance with current regulatory reporting requirements.

Sincerely,

Scott P. Tarra Managing Principal

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar Quick Guide JANUARY

FEBRUARY

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APRIL S

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JULY S

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SEPTEMBER

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OCTOBER

NOVEMBER

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DECEMBER

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31 [ ]= Compliance Requirements/Due Date [ ]= Market Holiday/Market Close

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

January 01

New Year's Day (observed) FINRA/NYSE Market Holiday

03

2017 Final Renewal Statement Availability FINRA Renewal Program Calendar -- Investment advisers must confirm full payment of their renewal fees as reflected on their Final Renewal Statement. Overpayments are transferred to firms' Flex-Funding Account. Refund requests should be made from this account through E-Bill. Final Statements are available for viewing and printing through E-Bill. Renewal reports can be requested through Web CRD/IARD.

16

Martin Luther King Jr. Day FINRA/NYSE Market Holiday

20

DEADLINE for receipt of Final Statement payments FINRA Renewal Program Calendar -- Firms with sufficient monies in their Flex Funding Accounts will have funds automatically transferred to their Renewal Accounts to cover total renewal fees owed. Transfers will be conducted every day until any outstanding renewal assessment is satisfied.

26

Monthly Financials (as of Dec. 31, 2016) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement

February 09

Annual Entitlement User Accounts Certification Process (Super Account Administrator) FINRA Annual Entitlement User Accounts Certification Process -- Certification process must be completed by the designated Super Account Administrator or SAA through IARD system.

14

Form 13F Filing (First Time Filers; Q4 2016) Section 13(f) of the Securities Exchange Act of 1934 -- Registered investment advisers must file a Form 13F if they exercise investment discretion with respect to $100 million or more in certain identified 13F securities within 45 days after the end of the year in which the adviser reaches the $100 million filing threshold. The measurement date for calculating $100 million threshold is as of the last calendar day of any month in a given year. Thereafter, advisers must make 13F filings within 45 days after end of calendar quarter.

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

February 14

Form 13H Filing (First Time Filers; Q4 2016) Rule 13h-1(a)(1) -- Large Trader Reporting- Registered investment advisers meeting the SEC's "large trader" thresholds (i.e. trades (i) 2 million shares or $20 million FMV daily or (ii) 20 million shares or $200 million FMV monthly) are required to file an initial Form 13H with the SEC within 10 days of triggering the threshold. Large traders also need to amend Form 13H annually within 45 days of year-end and make quarterly update filings to the extent that information changes.

14

Schedule 13G/D and Section 16 Filings Exchange Act Sections 13(d) and 13(g) and Regulation 13D-G -- Investment advisers who exercise investment discretion over funds that are beneficial owners of 5% or more of a registered voting equity security must report these positions on Schedule 13G or Schedule 13D. Note: Schedule 13G filings must be updated annually within 45 days of the end of the year. Schedule 13D filings need to be amended when any material change (including a change of 1% or more of the securities reported as beneficially owned) in the prior Schedule 13D has occurred. Any necessary Section 16 filings (Form 3, 4 or 5) also should be reviewed.

20

Presidents' Day FINRA/NYSE Market Holiday.

24

Monthly Financials (as of Jan. 31, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

March 01

Commodity Pool Operator (CPO) Exemption CFTC Regulation 4.13(a)(3) -- Investment advisers relying on the exemption from registration with the U.S. Commodity Futures Trading Commission (CFTC) pursuant to the "de minimis exemption" of CFTC Regulation 4.13(a)(3), must reaffirm their claim of exemption with the National Futures Association (NFA) each year annually within 60 days of the end of the calendar year.

23

Monthly Financials (as of Feb. 28, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

March 31

Form ADV Part 1 & 2A/B Annual Update (FYE Dec. 31, 2016) Rule 204-1 -- Amendments to Application for Registration- Registered investment advisers and exempt reporting advisers (ERAs) must file an annual amendment to Form ADV with the SEC and/or state securities authorities within 90 days of their fiscal year end. Note that any material change to an adviser's business throughout the course of the year requires amending the Form ADV promptly after the change.

31

Special Note on California Private Fund Adviser Exemption California Code of Regulations, Rule 260.204.9 -- California advisers that are eligible for exemption from adviser registration with the California Department of Business Oversight (DBO) must file Part 1 of the Adviser's Form ADV with the DOC within 90 days of fiscal year end.

April 14

Good Friday NYSE Market Holiday.

15

Q1 2017 Compliance Review & Recap Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a monthly compliance review and recap of select areas of their advisory business within 15 days after the end of each month • • • • • • • •

Sample Review of New Advisory Accounts/Agreements/Documentation -- Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers); Rule 204-3 (Written Disclosure Statements) Sample Review of OFAC Checks & Customer Identity on New Accounts -- *Best Practice -- see Bank Secrecy Act of 1970, Money Laundering Control Act of 1986 or USA PATRIOT Act Sample Review of Advisory Transactions -- Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers Review of Newly Hired/Terminated IA Reps -- Ref. Rule 206(4)-4 -- Financial and Disciplinary Information that Investment Advisers Must Disclose to Clients Review of Customer Complaints -- Rule 204-2(a)(7) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Gifts & Gratuities -- Rule 204A-1 -- Investment Adviser Code of Ethics Sample Review of Activity/Exception Reports -- Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Written/Electronic Business Related Correspondence -- Rule 204-2(a)(7) & (11) & 204-2(g) -- Books and Records to Be Maintained by Investment Advisers

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

April 15

Q1 2017 Compliance Review & Recap (Cont.)

Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a monthly compliance review and recap of select areas of their advisory business within 15 days after the end of each month • • • • • • •

• • •

25

Sample Review of Advertising Materials -- Rule 206(4)-1 -- Advertisements by Investment Advisers Sample Review of Social Media by Firm/Access Persons -- SEC IM Guidance on the Testimonial Rule and Social Media (March 2014; No. 2014-04) Sample Review of Personal Securities Transactions & Qtly Reports -- Rule 204A-1-- Investment Adviser Code of Ethics (Quarterly Transaction Reports) Sample Review of Outside Business Activities -- Rule 204A-1 -- Investment Adviser Code of Ethics; Form U4 Instructions Review and Update Restricted Securities & Watch List -- Rule 204A-1 -- Investment Adviser Code of Ethics Review Compliance & Cybersecurity Procedures for Material Updates -- Rule 206(4)-7 -- Compliance Procedures and Practices; SEC OCIE 2015 Cybersecurity Examination Initiative (Volume IV, Issue 8; September 15, 2015) Review Business Continuity/Disaster Recovery Plan for Material Updates -- Rule 206(4)-7 -- Compliance Procedures and Practices; also see Joint Review of Business Continuity and Disaster Recovery of Firms conducted by the SEC, CFTC and FINRA (Aug. 16, 2013) Review Code of Ethics for Material Update -- Rule 204A-1 -- Investment Adviser Code of Ethic Review Privacy Policy for Material Updates -- Reg. S-P -- Privacy of Consumer Financial Information Review Firm Agreements (e.g. Sub-Adviser, Solicitation, Vendor, etc.) -- Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers

Monthly Financials (as of Mar. 31, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

30

Delivery of Updated Form ADV Part 2A (Brochure) and Form ADV Part 2B (Brochure Supplement) to advisory clients Rue 204-3(b)(2) -- Delivery of brochures and brochure supplements- Investment Advisers must deliver to each client, annually within 120 days after the end of your fiscal year and without charge, if there are material changes in your brochure since your last annual updating amendment.

30

Annual Privacy Policy Notice SEC Regulation S-P -- Privacy of Consumer Financial Information- Current privacy policies should be disclosed to advisory clients who are natural persons on an annual basis; this is generally completed concurrently with the delivery of the Form ADV Part 2A (Brochure) and Form ADV Part 2B (Brochure Supplement).

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

April 30

Mailing of Annual Disclosure Documents to Clients (BCP Statement, etc.)

Additional disclosure documents should be provided to advisory clients who are natural persons on an annual basis; this is generally completed concurrently with the delivery of the Form ADV Part 2A (Brochure) and Form ADV Part 2B (Brochure Supplement)

30

Form PF Filing--Small private fund advisers (FYE December 31, 2016) Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers that have at least $150 million in private fund assets under management but do not exceed a “large adviser” threshold must file Form PF only once a year, within 120 days of the end of the fiscal year.

30

Form PF Filing-- Large private equity advisers (FYE December 31, 2016) Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers with at least $2 billion in assets under management attributable to private equity funds must file Form PF annually within 120 days of the end of the fiscal year.

30

Delivery of Audited Financial Statements (FYE December 31, 2016) Rule 206(4)-2(b)(4)(i) -- Custody or Possession of Funds or Securities of Clients by Investment Advisors- Registered investment advisers relying on the “audited financials exception” to the account statement delivery and independent verification requirements of the Custody Rule must deliver such audited financial statements for their fund to investors within 120 days of the end of the fund’s fiscal year.

30

Custody Rule Annual Audit (FYE December 31, 2016) Rule 206(4)-2(a)(4)(i) -- Custody or Possession of Funds or Securities of Clients by Investment Advisors- Registered investment advisers must comply with certain custody procedures by having an independent public accountant registered with the Public Company Accounting Oversight Board prepare audited financial statements in accordance with GAAP and sending such audited financial statements to investors within 120 days after the fund’s fiscal year-end.

May 15

Form 13F Filing (Q1 2017) Section 13(f) of the Securities Exchange Act of 1934 -- Registered investment advisers must file a Form 13F if they exercise investment discretion with respect to $100 million or more in certain identified 13F securities within 45 days after the end of the year in which the adviser reaches the $100 million filing threshold. The measurement date for calculating $100 million threshold is as of the last calendar day of any month in a given year. Thereafter, advisers must make 13F filings within 45 days after end of calendar quarter.

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

May 15

Form 13H Filing (Q1 2017) Rule 13h-1(a)(1) -- Large Trader Reporting- Registered investment advisers meeting the SEC's "large trader" thresholds (i.e. trades (i) 2 million shares or $20 million FMV daily or (ii) 20 million shares or $200 million FMV monthly) are required to file an initial Form 13H with the SEC within 10 days of triggering the threshold. Large traders also need to amend Form 13H annually within 45 days of year-end and make quarterly update filings to the extent that information changes.

23

Monthly Financials (as of Apr. 30, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement

26

Friday before Memorial Day (3 p.m. early close) FINRA Market Holiday.

29

Memorial Day FINRA/NYSE Market Holiday.

30

Form PF Filing-- Large hedge fund advisers (Q1 2017) Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers with at least $1.5 billion in assets under management attributable to hedge funds must file Form PF to update information regarding the hedge funds they manage within 60 days of the end of each fiscal quarter.

June 07

Applicability Date for DOL Definition of the Term ‘‘Fiduciary’’; Conflict of Interest Rule The Department of Labor (DOL) has determined an effective Date: June 7, 2016 (60 days after the scheduled Federal Register publication date of April 8).

09

Applicability Date for DOL Definition of the Term ‘‘Fiduciary’’; Conflict of Interest Rule The Department of Labor (DOL) has determined an applicability date of June 9, 2017 (delayed from the original April 10 Applicability Date), with a further transition period for many BIC provisions and revisions to PTE 84-24 other than the impartial conduct standards until January 1, 2018, and a conditional grandfather rule for certain arrangements existing before June 9, 2017 .

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

June 23

Monthly Financials (as of May 31, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

July 03

Day before Independence Day (1 p.m. early close) FINRA/NYSE Market Holiday.

04

Independence Day FINRA/NYSE Market Holiday.

15

Q2 2017 Compliance Review & Recap Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a monthly compliance review and recap of select areas of their advisory business within 15 days after the end of each month • • • • • • • • • • • •

Sample Review of New Advisory Accounts/Agreements/Documentation -- Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers); Rule 204-3 (Written Disclosure Statements) Sample Review of OFAC Checks & Customer Identity on New Accounts -- *Best Practice -- see Bank Secrecy Act of 1970, Money Laundering Control Act of 1986 or USA PATRIOT Act Sample Review of Advisory Transactions -- Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers Review of Newly Hired/Terminated IA Reps -- Ref. Rule 206(4)-4 -- Financial and Disciplinary Information that Investment Advisers Must Disclose to Clients Review of Customer Complaints -- Rule 204-2(a)(7) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Gifts & Gratuities -- Rule 204A-1 -- Investment Adviser Code of Ethics Sample Review of Activity/Exception Reports -- Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Written/Electronic Business Related Correspondence -- Rule 204-2(a)(7) & (11) & 204-2(g) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Advertising Materials -- Rule 206(4)-1 -- Advertisements by Investment Advisers Sample Review of Social Media by Firm/Access Persons -- SEC IM Guidance on the Testimonial Rule and Social Media (March 2014; No. 2014-04) Sample Review of Personal Securities Transactions & Qtly Reports -- Rule 204A-1-- Investment Adviser Code of Ethics (Quarterly Transaction Reports) Sample Review of Outside Business Activities -- Rule 204A-1 -- Investment Adviser Code of Ethics; Form U4 Instructions

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

July 15

Q2 2017 Compliance Review & Recap (Cont.)

Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a monthly compliance review and recap of select areas of their advisory business within 15 days after the end of each month • • •

• • •

15

Review and Update Restricted Securities & Watch List -- Rule 204A-1 -- Investment Adviser Code of Ethics Review Compliance & Cybersecurity Procedures for Material Updates -- Rule 206(4)-7 -- Compliance Procedures and Practices; SEC OCIE 2015 Cybersecurity Examination Initiative (Volume IV, Issue 8; September 15, 2015) Review Business Continuity/Disaster Recovery Plan for Material Updates -- Rule 206(4)-7 -- Compliance Procedures and Practices; also see Joint Review of Business Continuity and Disaster Recovery of Firms conducted by the SEC, CFTC and FINRA (Aug. 16, 2013) Review Code of Ethics for Material Update -- Rule 204A-1 -- Investment Adviser Code of Ethic Review Privacy Policy for Material Updates -- Reg. S-P -- Privacy of Consumer Financial Information Review Firm Agreements (e.g. Sub-Adviser, Solicitation, Vendor, etc.) -- Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers

Form PF Filing-- Large liquidity fund advisers (Q2 2017) Rule 204(b)-1 -- Reporting by investment advisers to private funds; Rule 2a-7 -- Money Market Funds- Liquidity fund advisers with at least $1 billion in combined assets under management attributable to liquidity funds and registered money market funds must file Form PF to update information regarding the liquidity funds they manage within 15 days of the end of each fiscal quarter.

26

Monthly Financials (as of Jun. 30, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

August 14

Form 13F Filing (Q2 2017) Section 13(f) of the Securities Exchange Act of 1934 -- Registered investment advisers must file a Form 13F if they exercise investment discretion with respect to $100 million or more in certain identified 13F securities within 45 days after the end of the year in which the adviser reaches the $100 million filing threshold. The measurement date for calculating $100 million threshold is as of the last calendar day of any month in a given year. Thereafter, advisers must make 13F filings within 45 days after end of calendar quarter.

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

August 14

Form 13H Filing (Q2 2017) Rule 13h-1(a)(1) -- Large Trader Reporting- Registered investment advisers meeting the SEC's "large trader" thresholds (i.e. trades (i) 2 million shares or $20 million FMV daily or (ii) 20 million shares or $200 million FMV monthly) are required to file an initial Form 13H with the SEC within 10 days of triggering the threshold. Large traders also need to amend Form 13H annually within 45 days of year-end and make quarterly update filings to the extent that information changes.

23

Monthly Financials (as of Jul. 31, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

29

Form PF Filing-- Large hedge fund advisers (Q2 2017) Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers with at least $1.5 billion in assets under management attributable to hedge funds must file Form PF to update information regarding the hedge funds they manage within 60 days of the end of each fiscal quarter.

September 01

Friday before Labor Day (3 p.m. early close) FINRA Market Holiday.

04

Labor Day FINRA/NYSE Market Holiday.

26

Monthly Financials (as of Aug. 31, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

October 01

Amendments to Form ADV and Investment Advisers Act Rule Form ADV & SEC Rule 204-2 Amendments; Technical Amendments to Rule 203A-5; Rule 202(a)(11)(G)-1(e); Rule 203-1(e); and Rule 203-1(b), Rule 204-1(c) and Rule 204-3(g) -- Any adviser filing an initial Form ADV or an amendment to an existing Form ADV on or after October 1, 2017 will be required to provide responses to the form revisions; amendments to the books and records rule, 275.204-2, will apply to communications distributed after October 1, 2017.

01

Amendments to Form ADV and Investment Advisers Act Rule In a letter to the Investment Adviser Association (IAA), the SEC stated that investment advisers acting pursuant to a standing letter of instruction or other similar asset transfer authorization (SLOA) established by a client with a qualified custodian would be deemed to have custody of client assets for purposes of Rule 206(4)-2 (the “Custody Rule”). Nonetheless, the SEC said it would not recommend enforcement action if an adviser, acting pursuant to a SLOA, did not obtain a surprise examination of custody accounts under certain circumstances. The no-action relief does not extend to investment advisers who are deemed to have custody of client assets because they have the ability to authorize payment of their own advisory fees. Beginning with the next annual updating amendment after October 1, 2017, an investment adviser should include client assets that are subject to a SLOA that result in custody in its response to Item 9 of Form ADV. For most investment advisers, this disclosure will be required for their annual filing in the first quarter of 2018.

09

Columbus Day Holiday/Market Open.

15

Q3 2017 Compliance Review & Recap Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a monthly compliance review and recap of select areas of their advisory business within 15 days after the end of each month • • • • • • • • • •

Sample Review of New Advisory Accounts/Agreements/Documentation -- Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers); Rule 204-3 (Written Disclosure Statements) Sample Review of OFAC Checks & Customer Identity on New Accounts -- *Best Practice -- see Bank Secrecy Act of 1970, Money Laundering Control Act of 1986 or USA PATRIOT Act Sample Review of Advisory Transactions -- Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers Review of Newly Hired/Terminated IA Reps -- Ref. Rule 206(4)-4 -- Financial and Disciplinary Information that Investment Advisers Must Disclose to Clients Review of Customer Complaints -- Rule 204-2(a)(7) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Gifts & Gratuities -- Rule 204A-1 -- Investment Adviser Code of Ethic Sample Review of Activity/Exception Reports -- Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Written/Electronic Business Related Correspondence -- Rule 204-2(a)(7) & (11) & 204-2(g) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Advertising Materials -- Rule 206(4)-1 -- Advertisements by Investment Advisers Sample Review of Social Media by Firm/Access Persons -- SEC IM Guidance on the Testimonial Rule and Social Media (March 2014; No. 2014-04)

2017 Investment Adviser Compliance Calendar Prepared by Connexien LLC

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2017 Investment Adviser Compliance Calendar

October 15

Q3 2017 Compliance Review & Recap (Cont.)

Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a monthly compliance review and recap of select areas of their advisory business within 15 days after the end of each month • • • • •

• • •

15

Sample Review of Personal Securities Transactions & Qtly Reports -- Rule 204A-1-- Investment Adviser Code of Ethics (Quarterly Transaction Reports) Sample Review of Outside Business Activities -- Rule 204A-1 -- Investment Adviser Code of Ethics; Form U4 Instructions Review and Update Restricted Securities & Watch List -- Rule 204A-1 -- Investment Adviser Code of Ethics Review Compliance & Cybersecurity Procedures for Material Updates -- Rule 206(4)-7 -- Compliance Procedures and Practices; SEC OCIE 2015 Cybersecurity Examination Initiative (Volume IV, Issue 8; September 15, 2015) Review Business Continuity/Disaster Recovery Plan for Material Updates -- Rule 206(4)-7 -- Compliance Procedures and Practices; also see Joint Review of Business Continuity and Disaster Recovery of Firms conducted by the SEC, CFTC and FINRA (Aug. 16, 2013) Review Code of Ethics for Material Update -- Rule 204A-1 -- Investment Adviser Code of Ethic Review Privacy Policy for Material Updates -- Reg. S-P -- Privacy of Consumer Financial Information Review Firm Agreements (e.g. Sub-Adviser, Solicitation, Vendor, etc.) -- Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers

Form PF Filing-- Large liquidity fund advisers (Q3 2017) Rule 204(b)-1 -- Reporting by investment advisers to private funds; Rule 2a-7 -- Money Market Funds- Liquidity fund advisers with at least $1 billion in combined assets under management attributable to liquidity funds and registered money market funds must file Form PF to update information regarding the liquidity funds they manage within 15 days of the end of each fiscal quarter.

25

Monthly Financials (as of Sept. 30, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

November 11

Veterans Day Holiday/Market Closed.

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2017 Investment Adviser Compliance Calendar

November 13

Preliminary Statements Available FINRA Annual Renewal Program Calendar -- Preliminary Statements are available for viewing and printing through E-Bill.

Renewal reports can be requested through Web CRD/IARD.

14

Form 13F Filing (Q3 2017) Section 13(f) of the Securities Exchange Act of 1934 -- Registered investment advisers must file a Form 13F if they exercise investment discretion with respect to $100 million or more in certain identified 13F securities within 45 days after the end of the year in which the adviser reaches the $100 million filing threshold. The measurement date for calculating $100 million threshold is as of the last calendar day of any month in a given year. Thereafter, advisers must make 13F filings within 45 days after end of calendar quarter.

14

Form 13H Filing (Q3 2017) Rule 13h-1(a)(1) -- Large Trader Reporting- Registered investment advisers meeting the SEC's "large trader" thresholds (i.e. trades (i) 2 million shares or $20 million FMV daily or (ii) 20 million shares or $200 million FMV monthly) are required to file an initial Form 13H with the SEC within 10 days of triggering the threshold. Large traders also need to amend Form 13H annually within 45 days of year-end and make quarterly update filings to the extent that information changes.

22

Day before Thanksgiving Day (3 p.m. early close) FINRA Market Holiday.

23

Thanksgiving Day FINRA/NYSE Market Holiday.

24

Day after Thanksgiving Day (1 p.m. early close) FINRA/NYSE Market Holiday.

27

Monthly Financials (as of Oct. 31, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

29

Form PF Filing-- Large hedge fund advisers (Q3 2017) Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers with at least $1.5 billion in assets under management attributable to hedge funds must file Form PF to update information regarding the hedge funds they manage within 60 days of the end of each fiscal quarter.

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December 14

DEADLINE for receipt of Preliminary Statement payments FINRA Annual Renewal Program Calendar -- DEADLINE for receipt of Preliminary Statement payments. Firms with sufficient monies in their Flex-Funding Account will have funds automatically transferred to their Renewal Account to cover total renewal fees owed. Transfers will be conducted every day until Web CRD/IARD shuts down for year-end processing.

25

Christmas Day FINRA/NYSE Market Holiday.

26

Monthly Financials (as of Nov. 30, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

27

LAST DAY to submit form filings prior to year-end FINRA Annual Renewal Program Calendar -- LAST DAY to submit form filings prior to year-end. Web CRD/IARD is available from 5 a.m. until 6 p.m., Eastern Time (ET).

28

Web CRD/IARD is unavailable due to Final Statement and renewals processing FINRA Annual Renewal Program Calendar -- Web CRD/IARD is unavailable due to Final Statement and renewals processing.

29

Web CRD/IARD is available for QUERY-only and the creation of "Pending" filings FINRA Annual Renewal Program Calendar -- Web CRD/IARD is available for QUERY-only and the creation of "Pending" filings.

31

Year-End Compliance Review Checklist Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a year-end compliance review checklist to ensure that all applicable compliance requirements were completed for the current year.

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January 2018 15

Q4 2017 Compliance Review & Recap Rule 206(4)-7 -- Compliance Procedures and Practices- Investment advisers are encouraged to conduct a monthly compliance review and recap of select areas of their advisory business within 15 days after the end of each month • • • • • • • • • • • • • • •

• • •

Sample Review of New Advisory Accounts/Agreements/Documentation -- Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers); Rule 204-3 (Written Disclosure Statements) Sample Review of OFAC Checks & Customer Identity on New Accounts -- *Best Practice -- see Bank Secrecy Act of 1970, Money Laundering Control Act of 1986 or USA PATRIOT Act Sample Review of Advisory Transactions -- Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers Review of Newly Hired/Terminated IA Reps -- Ref. Rule 206(4)-4 -- Financial and Disciplinary Information that Investment Advisers Must Disclose to Clients Review of Customer Complaints -- Rule 204-2(a)(7) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Gifts & Gratuities -- Rule 204A-1 -- Investment Adviser Code of Ethics Sample Review of Activity/Exception Reports -- Rule 204-2(a)(3) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Written/Electronic Business Related Correspondence -- Rule 204-2(a)(7) & (11) & 204-2(g) -- Books and Records to Be Maintained by Investment Advisers Sample Review of Advertising Materials -- Rule 206(4)-1 -- Advertisements by Investment Advisers Sample Review of Social Media by Firm/Access Persons -- SEC IM Guidance on the Testimonial Rule and Social Media (March 2014; No. 2014-04) Sample Review of Personal Securities Transactions & Qtly Reports -- Rule 204A-1-- Investment Adviser Code of Ethics (Quarterly Transaction Reports) Sample Review of Outside Business Activities -- Rule 204A-1 -- Investment Adviser Code of Ethics; Form U4 Instructions Review and Update Restricted Securities & Watch List -- Rule 204A-1 -- Investment Adviser Code of Ethics Review Compliance & Cybersecurity Procedures for Material Updates -- Rule 206(4)-7 -- Compliance Procedures and Practices; SEC OCIE 2015 Cybersecurity Examination Initiative (Volume IV, Issue 8; September 15, 2015) Review Business Continuity/Disaster Recovery Plan for Material Updates -- Rule 206(4)-7 -- Compliance Procedures and Practices; also see Joint Review of Business Continuity and Disaster Recovery of Firms conducted by the SEC, CFTC and FINRA (Aug. 16, 2013) Review Code of Ethics for Material Update -- Rule 204A-1 -- Investment Adviser Code of Ethic Review Privacy Policy for Material Updates -- Reg. S-P -- Privacy of Consumer Financial Information Review Firm Agreements (e.g. Sub-Adviser, Solicitation, Vendor, etc.) -- Rule 204-2(a)(10) -- Books and Records to Be Maintained by Investment Advisers

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January 2018 15

Form PF Filing-- Large liquidity fund advisers (Q4 2017) Rule 204(b)-1 -- Reporting by investment advisers to private funds; Rule 2a-7 -- Money Market Funds- Liquidity fund advisers with at least $1 billion in combined assets under management attributable to liquidity funds and registered money market funds must file Form PF to update information regarding the liquidity funds they manage within 15 days of the end of each fiscal quarter.

25

Monthly Financials (as of Dec. 31, 2017) Rule 204-2 -- Books and Records to Be Maintained by Investment Advisers Investment advisers should complete their monthly financial statements generally no later than 17 business days after month-end. Note: State investment advisers should also complete a net capital calculation in those states that maintain a net capital requirement.

February 2018 14

Form 13F Filing (Q4 2017) Section 13(f) of the Securities Exchange Act of 1934 -- Registered investment advisers must file a Form 13F if they exercise investment discretion with respect to $100 million or more in certain identified 13F securities within 45 days after the end of the year in which the adviser reaches the $100 million filing threshold. The measurement date for calculating $100 million threshold is as of the last calendar day of any month in a given year. Thereafter, advisers must make 13F filings within 45 days after end of calendar quarter.

14

Form 13H Filing (Q4 2017) Rule 13h-1(a)(1) -- Large Trader Reporting- Registered investment advisers meeting the SEC's "large trader" thresholds (i.e. trades (i) 2 million shares or $20 million FMV daily or (ii) 20 million shares or $200 million FMV monthly) are required to file an initial Form 13H with the SEC within 10 days of triggering the threshold. Large traders also need to amend Form 13H annually within 45 days of year-end and make quarterly update filings to the extent that information changes.

March 2018 01

Form PF Filing-- Large hedge fund advisers (Q4 2017) Rule 204(b)-1 -- Reporting by investment advisers to private funds- Advisers with at least $1.5 billion in assets under management attributable to hedge funds must file Form PF to update information regarding the hedge funds they manage within 60 days of the end of each fiscal quarter.

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2017 Investment Adviser Compliance Calendar About Us At Connexien, we help financial service firms save time by offering a better way to connect with the experts they need the most. Through our intelligently designed platform, we connect banks, broker/dealers, investment advisers and insurance companies with our network of services providers, consultants and experts who provide high performance solutions to address the most basic to complex project needs. We are the new marketplace for on-demand skilled services for the financial services industry.

For more information on this topic or other related matters, please contact: Scott P. Tarra Managing Principal Tel +1 949 338 8192 starra@connexien.com

Connexien LLC 19100 Von Karman Ave., Suite 950 Irvine, California 92612 Tel +1 949 771 0344 Fax +1 949 608 3636 www.connexien.com

This publication contains general information only and Connexien is not, by means of this publication, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This publication is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor. Connexien shall not be responsible for any loss sustained by any person who relies on this publication.

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