Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds

February 12, 2024

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the Financial Industry Regulatory Authority (indirectly) and the National Futures Association) impose reporting and compliance obligations on asset managers and investment funds. Some of these requirements apply only to U.S.-registered investment advisers, commodity pool operators or commodity trading advisors, but others apply to investment managers and funds that are located outside the United States and are not registered in the United States.

This Dechert OnPoint provides a brief description of some of these requirements and serves as a reminder of the need for compliance. However, it is not intended to provide a complete discussion of all reporting and compliance requirements that may be applicable to investment advisers and private funds.

Contributors

The authors would like to thank Joshua Anifowoshe, Stephen Choi, Katherine Coghlan, Jennifer A. DiNuccio, Phillip Garber, Leah Herring, Jannet Jassi, Yanyu Mao, Michael McGrail, Michael Murphy, Jennifer O’Brien, Emily Parks, Monica R. Patel, Tyler H. Payne, Louis Rosenbaum, Olivia R. Sedita, Lauren E. Vineyard and Inna Vysman for their contributions to this OnPoint.