Registered investment advisers and exempt reporting advisers are required to file their annual Form ADV amendment within 90 days after their fiscal year end. Private fund managers typically have Dec. 31 fiscal year ends, meaning their annual amendments are filed at the end of March of the following year. Because 2024 is a leap year, February has an extra day. Accordingly, managers with Dec. 31 fiscal year ends must file their upcoming annual Form ADV amendment by Saturday, March 30, 2024. While IARD, the system through which managers prepare and file Form ADV, is typically open on Saturdays, managers should consider filing by Friday, March 29, 2024, to account for any contingencies.

If you have any questions concerning this Alert, please contact your attorney at Schulte Roth & Zabel.

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