Seward & Kissel briefing: 2021 annual reminders

On 2 February 2021, Seward & Kissel, our alliance firm for hedge fund and asset management work, published a memorandum highlighting U.S. annual requirements coming up in 2021 that may be relevant to your business.

The memorandum is divided into four sections dealing, respectively, with the requirements that apply t0:

• all investment advisers, even if not registered with the SEC (Section 1)

• SEC registered advisers and exempt reporting advisers (Section 2)

• SEC Registered Advisers (Section 3) and

• advisers that trade futures, commodities, certain swaps and other commodity interests (Section 4).

Sections 2 to 4 apply to investment advisers to the extent that the requirements are relevant to their business model.

For more information, please contact Lucian Firth, Richard Perry or Devarshi Saksena or speak to an attorney at Seward & Kissel.