Compliance Corner Q4‑2024: Regulatory Filings and Other Considerations Hedge Fund Managers Should Note in the Coming Quarter

At the end of the calendar year, hedge fund managers may be busy wrapping up the ends of their fiscal years by arranging for Custody Rule audits, conducting annual compliance reviews, making required regulatory filings, handling year-end redemptions, making various tax elections, calculating fund expenses and conducting performance reviews of employees. Therefore, it is never too soon to start planning for the tasks that lie ahead in the last quarter of the year. This latest installment of the Hedge Fund Law Report’s quarterly compliance update highlights upcoming filing deadlines and reporting requirements fund managers should be aware of during the fourth quarter. This guest article by ACA Group consultants Grazia Gatti, Luis Garcia and Dan Campbell also includes information on upcoming amendments to Schedule 13D and 13G filings; recent SEC enforcement cases focusing on Custody and Marketing Rule compliance; and the SEC Division of Examination’s recent sweep of investment advisers to assess their implementation of a shortened standard settlement time for securities transactions. In addition, the 2024 regulatory filings calendar prepared by ACA Group, which is designed to help hedge fund managers stay on top of important filing obligations, is available here. For more from ACA Group, see “Compliance Program Implementation: Compliance Calendars and Testing” (Jul. 18, 2024); and “Testing Is an Integral Component of Compliance Programs” (May 9, 2024).

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