April Bulletin

Updated: Sep 7

It seems February for CFTC (Exemption Registration), March for SEC (Annual ADV) and April for SFC. Following the new format Business Risk Management Questionnaire April has a new entrant in an already busy month. Preparation is key. For those who have completed their annual compliance programmes from 2020 it should be a straightforward reporting process. For others, there may still be some challenges.


Key Deadlines coming up in April

  • SFC Annual Audit Submissions for firms with 31st December deadlines approach

Annual Audit Deadlines for firms with Calendar years end approach at the end of April. Extensions for unusual circumstances may be granted but you need to get extension requests in early.

  • SFC Business Risk Management Questionnaire: Timing

Auditors usually work with our clients on their Financial Audit Submission and we have been assisting with the Business Risk Management Questionnaire ("BRMQ"). Sometimes auditors request to review the BRMQ. The SFC highlights in their FAQ that there is no obligation for auditors to provide an opinion as part of the Audit but some do ask. Firms should check in with their auditors about their approach in particular if it will impact timing in any way.


  • SFC EDSP Update

There remains some uncertainty about the best approach with regards to submitting approval requests for the use of Electronic Data Service Providers. Either by draft paper form or online via other notifications firms are still in process of submitting their requests for approval. Such uncertainty should not create a delay to the submission but we have noted some delays in completing reviews


  • SFC Asset Management Survey Deadline

Upcoming deadline for completion of Asset Management Survey which is due 16th April.


Some other issues for your consideration


Other general issues on the horizon

  • SFC FRR Form 12 - There will be some updates to the Financial Regulatory Reporting Form to be implemented from July 2021. See changes here. Firms should discuss relevant changes with their accountants. In particular firms should be aware of New Form 12 which requires more detailed analysis of your client types and strategies for reporting from July onwards,

  • LIBOR transition is well on its way. We are encouraging clients to book time with their derivative lawyers if they have not already been contacted by their counterparties.

  • ESG: Unless you have been under a blanket for the winter, the pressure to prepare and comply is ever increasing.

Some Bigger Background Issues

  • Market Volatility - Generally Market Volatility appears to be on the increase - Check in with portfolio risk

  • Credit and Counterparty Risk Issues - Some counterparties have taken a beating. It is worth considering your exposure monitoring

  • Recent Cyber Attacks - Have you, your service providers or your staff been affected by Solar Winds, Microsoft Exchange, Facebook data leaks. It is worth checking in

  • Market Manipulation issues - Continued focus on market misconduct

Get in touch for discussion of your Governance Risk and Compliance needs


Clients should refer to their inbox for more details on the issues highlighted above including some detailed updates on issues relating to responses on the BRMQ.

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