Tips for Creating an EOY Compliance Checklist (Part One of Two)

The first and last quarters of any year are among the busiest of a CCO’s calendar, as well as those of their respective colleagues. The sheer number of reports, filings, disclosures, deadlines, reviews and other tasks to be completed increases the probability of something falling through the cracks, which ultimately might be revealed at great cost during an SEC examination. The rigors of that six-to-seven-month stretch can be eased by proper planning. As CCOs enter the year-end period (EOY), they would be well-served to have a plan for what must get done and when. This two-part series offers a roadmap of tasks that CCOs can use to develop their own EOY compliance checklist. This first article highlights why it is important for CCOs to use EOY compliance checklists; approaches CCOs can take to compile their checklists and calendars; and some of the documents, policies, procedures and filing requirements to address during an EOY review. The second article will offer tips about items to include in an EOY compliance checklist relating to personnel, regulatory developments, third parties and budgets, as well as ways to prepare for the first quarter of the new year. See our two-part series “A Checklist for Investment Advisers to Streamline and Organize Their Annual Compliance Program Reviews”: Part One (May 12, 2020); and Part Two (May 26, 2020).

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