Code of ethics reporting deadlines
SEC · Annually · Once every 12 months, on your date
Under Rule 204A-1, an SEC-registered investment adviser's code of ethics must require each access person to submit a holdings report within 10 days of becoming an access person and at least once every 12 months after that, and a transaction report no later than 30 days after each calendar quarter end (17 CFR 275.204A-1(b)).
Holdings reports
- Within 10 days of becoming an access person, with information current within 45 days before that date
- Then at least once every 12 months, on a date you select, with information current within 45 days before the report
Quarterly transaction reports
No later than 30 days after the end of each calendar quarter, covering at least every transaction in the quarter: January 30, April 30, July 30 and October 30.
Who's an access person
Supervised persons who have access to nonpublic information about clients' purchases and sales of securities or the holdings of any reportable fund, or who are involved in making securities recommendations to clients or have access to nonpublic recommendations. If providing investment advice is your main business, all your directors, officers and partners are presumed to be access persons.
Also on the calendar
The annual compliance review is a good point to check every report came in on time.
Get reminded before it's due
Regmindr tracks this alongside the rest of your compliance calendar, and emails your team before each deadline.
Sources
This page is a summary, not legal or regulatory advice. The rules in the sources above take precedence.