- Within 45 days after the end of each full calendar year; and
- Promptly after the end of any calendar quarter during which time any of the information contained in the previously filed Form 13H becomes inaccurate for any reason.
Investment advisers and broker-dealers with discretionary authority over client assets may want to consider performing a review of trading activity over the last 12 to 24 months to determine whether they may fall under the definition of large trader, thus being required to make Form 13H filings. Should such firms determine that filings maybe necessary, the following additional steps should be considered:
- Implementing controls to capture aggregated transaction information going forward; and
- Establishing policies and procedures covering requirements and compliance with Rule 13h-1.
For additional information on or assistance with Form 13H, please contact Jacko Law Group PC at (619) 298-2880.