Code of ethics reporting deadline calendar

Rule 204A-1 has every adviser registered, or required to be registered, with the SEC adopt a written code of ethics under which its access persons report their holdings and their trades, and the firm reviews them. Three reports carry dates. The calendar takes the year you enter and the annual date your firm picked, and dates all three for every access person, plus the initial and first annual reports of anyone who joined. What else the code must hold, from the conduct standard to the written acknowledgments, is in the guide to the investment adviser code of ethics.

The “as of” date is easy to miss. A holdings report filed on time can still fall short if the statement behind it is too old, so the calendar prints the oldest holdings date each report may use. It also dates the records side: each report is a record under Rule 204-2(a)(13)(i), kept at least five years from the end of the fiscal year in which it was made, the first two in an appropriate office of the adviser. The books and records retention calculator works the same period out for any other adviser record, and the guide to Rule 204-2 lists them all.

Take the tool’s default. A small adviser holds its annual holdings date on February 15, and a research analyst becomes an access person on March 15, 2027. The analyst’s initial report is due 10 days later, on March 25, and must show holdings as of January 29, 2027 or later: 45 days before the start date. The firm-wide annual report on February 15 can rest on statements dated January 1 or later, so a year-end statement works.

Two things stand out. Three of the eight dates fall on a weekend: January 30, 2027 is a Saturday, October 30 a Saturday and January 30, 2028 a Sunday. The rule text names no move to the next business day, so the calendar treats each as the last day; a firm may prefer to collect those reports by the Friday before. And the analyst’s first annual report is the firm’s February 15, 2028 date. The rule asks for one “at least once each 12-month period thereafter”; folding a new person into the firm’s own date, which always falls inside those 12 months, is our reading, not a rule sentence.

The calendar dates every report the rule can ask for. A firm’s code of ethics may drop some of them, because the rule says the code “need not require” three kinds:

• Any report on accounts over which the access person had no direct or indirect influence or control.
• A transaction report for trades made under an automatic investment plan, which the rule defines to include a dividend reinvestment plan.
• A transaction report that would duplicate broker trade confirmations or account statements the firm holds, so long as they arrive no later than 30 days after the quarter ends. Tick the broker statements box in the tool to see that condition beside the dates.

That last exception is where broker feeds come in when a firm chooses software; the comparison of personal trading compliance software reads each vendor’s own pages on feeds, pre-clearance and report reminders. Whatever arrives in place of a report is kept too: Rule 204-2(a)(13)(i) names “any information provided under paragraph (b)(3)(iii)” of the rule.

Some holdings never belong in a report. “Reportable security” leaves out direct obligations of the US government, bankers’ acceptances, bank CDs, commercial paper and high quality short-term debt, money market fund shares, shares of open-end funds other than reportable funds, and unit investment trusts invested only in such funds.

Every date in the calendar comes from one of three sentences in Rule 204A-1(b).

Note what the sentences leave to the firm. The annual date is “a date you select”, and the reports go to the chief compliance officer or other persons the code names. Rule 204A-1(a)(3) also has the firm review the reports, so the review belongs in the compliance program that Rule 206(4)-7 asks for and in the annual compliance review plan. The calendar is a reading of the rule text, not legal advice; check the dates with your compliance counsel before you publish them to staff.

Every rule the calendar uses, in the rule’s own words, with the paragraph to cite. Open a row to read it. The full text is on the eCFR for Rule 204A-1 and Rule 204-2.

To put these dates into a written code and manual, start from the RIA compliance manual template; to collect the reports in software rather than by email, the comparison of RIA compliance software reads each platform’s own pages on code-of-ethics reports beside the rest of the program.