2013 Annual Requirements for Investment Advisers Registered with the SEC

Investment advisers registered with the U.S. Securities and Exchange Commission (the “SEC”) have certain annual requirements under the U.S. Investment Advisers Act of 1940 (the “Advisers Act”). Some of these requirements may also apply to “exempt reporting advisers” or warrant consideration as best practices. This memo summarizes certain annual regulatory and compliance obligations, including a number of significant 2013 reporting or filing deadlines. In particular, in 2013 many advisers face the challenge of reporting for the first time on Form PF, a new informational form required in connection with certain private investment funds (discussed in greater detail below).

This memo also reminds advisers registered or required to be registered as commodity pool operators (“CPOs”) or commodity trading advisors (“CTAs”) with the U.S. Commodity Futures Trading Commission (the “CFTC”) of new CFTC reporting requirements, as well as National Futures Association (“NFA”) reporting requirements.

This update does not purport to be a comprehensive summary of all of the compliance obligations to which advisers are subject; please contact a member of Rimon’s Investment Funds Group to discuss these and other requirements under the Advisers Act, the Commodity Exchange Act and other regulations that may be applicable to investment advisers, CPOs or CTAs.

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