As a reminder, Rule 204-1 under the Investment Advisers Act of 1940 requires that all investment advisers amend their Form ADV filing at least annually, and do so within 90 days of the end of the adviser’s fiscal year. As highlighted by a recent email from the SEC to registered investment advisers, due to 2016 being a leap year, this requirement means that investment advisers with a Dec. 31 fiscal year end (representing a majority of the registered investment adviser community), are required to file this year’s annual ADV amendment not later than March 30, 2016. 2016 being a leap year will also affect other filings by registered investment advisers (and other SEC registrants), including, for example, Form PF filings by private fund advisers with Dec. 31 fiscal year ends and who are not subject to quarterly reporting (whose annual filings are due on April 29, 2016), and by certain large hedge fund advisers and large liquidity fund advisers with non-traditional fiscal year ends. Please contact your GT attorney for more information or if you have any questions regarding the impact of leap year on your regulatory filing calendar.

 

Tags: ADV, financial regulatory and compliance, Greenberg Traurig, gtlaw, gt_law, investment advisors, Investment Advisors Act of 1940, leap year, regulatory, regulatory filing, SEC
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Richard M. Cutshall Richard M. Cutshall

Richard M. Cutshall is Co-Chair of the firm’s Financial, Regulatory and Compliance Practice, Co-Chair of the firm’s Private Funds Group, and Co-Chair of the firm’s Investment Management Group. Rich has experience representing clients in a variety of investment management, general securities, and corporate

…

Richard M. Cutshall is Co-Chair of the firm’s Financial, Regulatory and Compliance Practice, Co-Chair of the firm’s Private Funds Group, and Co-Chair of the firm’s Investment Management Group. Rich has experience representing clients in a variety of investment management, general securities, and corporate matters, including the representation of mutual funds, ETFs, and other funds registered under the Investment Company Act of 1940; fund and ETF independent directors; unregistered investment funds; federally registered, state registered, and federally and state exempt investment advisers; broker-dealers; and an array of public and private companies.

Rich represents investment adviser clients at all stages of their life cycle, from concept and formation through registration, daily operation through wind-down and exiting the business, including representing investment adviser clients on both the buy-side and sell-side in M&A transactions. He also represents clients in all aspects of investment company practice, including organizing and forming new funds and ETFs, registering mutual funds and ETFs with the SEC, and the acquisition and merger of public funds.

In the course of representing investment advisers and public and private funds, Rich advises Greenberg Traurig’s clients on all aspects of securities regulatory compliance, particularly including new and existing SEC rules; SEC examination, regulatory, and investigative initiatives and sweeps; the SEC’s proposal, adoption, and implementation of new regulations, such as the recently rewritten investment adviser marketing rule; and finding compliance solutions related to the regulatory scheme applicable to investment advisers and investment funds, including implementing both novel and long-standing SEC regulatory guidance and interpretations. He also advises clients on the day-to-day aspects of corporate governance, board and adviser fiduciary responsibility, and SEC compliance, as well as assisting clients in all aspects of SEC and other regulatory examinations.

Rich has given presentations on and assists a variety of investment management clients with their compliance with anti-money laundering laws, and has performed annual independent third party audits of several clients’ anti-money laundering policies, programs and controls.

Rich also has experience representing clients in many industries in the sale or acquisition of businesses, formation of corporate entities, sophisticated contract negotiations, and in obtaining, renewing and renegotiating the terms of financing business operations. He routinely works with clients’ chief executive officers, chief financial officers, directors, and in-house general and assistant general counsels, including occasionally working from clients’ corporate headquarters upon request. Rich works with corporate and finance clients of all sizes, from startup family-run businesses and entrepreneurial endeavors to Fortune 500 clients. He also has experience representing clients across many industries, including health care, data management, retail product display and advertising design and manufacturing, industrial manufacturing, and real estate management and brokerage industries.

Read more about Richard M. Cutshall
Show more Show less
Related Posts
SEC Office
SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework
March 18, 2026
shutterstock_1363238018
Federal and State Efforts Intensify Focus on ‘Debanking’
January 13, 2026
shutterstock_591206291
NYDFS Final Cybersecurity Rules – MFA, Asset Inventory, and Third-Party Risk
November 11, 2025