It is that time of the year when hedge fund managers need to start making sure that everything is order in their back office for the beginning on next year. As there are many things that can slip through the cracks as focus is usually on trading and performance, we’ve provided a list of year end reminders. We will continue to post these reminders as they come closer.
Each year hedge fund managers which are registered as investment advisors (with either the SEC or state securities commission) will need to renew their IA application. To do this the adviser will need to post his yearly dues to the IARD system. Managers can gain access to this system on Monday, November 10 and are urged to have payment in by December 10 so that the payment will post by the deadline of December 12 (it usually takes a couple of days for payment to post to the account). Please also note that the payment should be posted to the “Renewal” account and not the “Daily” account.
Update of Form ADV and Form ADV Part II
Registered investment advisors must update their Form ADV and ADV Part II on a yearly basis. This must be completed within 90 days of the end of the advisor’s fiscal year, which is typically the end of the calendar year. We recommend that advisors go through the form on a question by question basis. The advisor’s attorney or compliance consultant can answer any questions which arise. This service is typically provided by consultants or attorneys on a flat fee, or sometimes hourly, basis.
Corporate Registered Agent
Most hedge funds are established as limited partnerships or limited liability companies in the state of Delaware and use local corporate registered agent services. Depending on the corporate agent, annual registered agent fees may be due soon. If you have any questions, you should talk with your corporate agent or attorney.
Offshore hedge funds will consist of one or more offshore entities. Typically these offshore entities will be formed by the local registered agent who will inform the manager when the yearly corporate and registered agent fees are due. If you have questions you should discuss with your contact person in the offshore jurisdiction.