Private fund advisers
Hedge fund compliance software and private equity compliance software that tracks every SEC and CFTC deadline as it moves
Hedge fund compliance software has one job most fund managers do by hand: knowing which SEC and CFTC obligations apply to your funds this quarter, and noticing when a date moves. Form PF has moved four times. Form SHO moved to 2028. ComplianceOfficer watches the releases at the source, keeps your filing calendar current and logs every review for the annual report. It costs $149 a month.
§ Live · Compliance scan
One free run. Nothing you pick is stored.
Hedge fund adviser, US · what a scan returns
- § 01 Compliance program and annual review
- § 02 Audited financials to investors
- § 03 Form PF amendments, now July 1, 2027 Changed
- § 04 Form SHO short position reporting
§ 02 · Dates that moved
Hedge fund compliance in 2026 is mostly about dates that will not sit still
Every rule below was adopted, scheduled, and then pushed back, some of them more than once. A compliance calendar built in January was wrong by spring. These are the tracks as of 2 October 2026.
Form PF amendments
SEC and CFTC, adopted Feb 2024
Extended Aug 31, 2026. A separate April 20, 2026 proposal would raise the filing threshold to $1 billion.
Form SHO short positions
Exchange Act Rule 13f-2
First filings due February 14, 2028 under the December 3, 2025 exemptive order.
Investment adviser AML program
FinCEN final rule, Aug 2024
Delay published in the Federal Register on January 2, 2026. A broader AML program reform proposal followed in April 2026.
Treasury clearing, cash then repo
SEC Treasury clearing rule, adopted Dec 2023
Reaches a fund's cash and repo trades through its direct-participant counterparties.
Each of those changes arrived as a press release or an exemptive order, not as a notice addressed to you. ComplianceOfficer reads them where they are published, changes the date in your register, and tells the person who owns that filing.
The filing year
Hedge fund regulatory compliance calendar for a December year end
The recurring filings for an SEC-registered adviser to hedge funds that has crossed the 13F and large hedge fund adviser thresholds and claims the CFTC 4.13(a)(3) exemption. Smaller managers drop some rows. Nobody drops all of them.
Jan
- 30 Code of ethics transaction reports (Q4)
Feb
- 14 Form 13F (Q4), Schedule 13G (QII and exempt), Form 13H annual
Mar
- 1 Form PF quarterly, large hedge fund adviser (60 days)
- 1 CFTC 4.13(a)(3) annual affirmation
- 31 Form ADV annual amendment
Apr
- 30 Audited fund financials to investors (120 days)
- 30 Code of ethics transaction reports (Q1)
May
- 15 Form 13F (Q1), Schedule 13G
- 30 Form PF quarterly
Jun
- · Mid-year: refresh the compliance risk assessment
Jul
- 30 Code of ethics transaction reports (Q2)
Aug
- 14 Form 13F (Q2), Schedule 13G
- 29 Form PF quarterly
Sep
- · Annual review fieldwork under Rule 206(4)-7
Oct
- 30 Code of ethics transaction reports (Q3)
Nov
- 14 Form 13F (Q3), Schedule 13G
- 29 Form PF quarterly
Dec
- · Annual holdings reports, on the date your code of ethics sets
- 31 Treasury cash clearing compliance date (2026)
Dates follow the rule text (13F and 13G within 45 days of quarter end, Form PF within 60 days for a large hedge fund adviser, Form ADV within 90 days of fiscal year end, audited financials within 120 days). Weekends and holidays shift the actual filing day, and the register shows the shifted date.
What applies to whom
Hedge fund compliance requirements by threshold
Most of the work in hedge fund compliance is scoping. A $300 million manager with no futures exposure and a $3 billion multi-strategy shop file very different things. The scan above starts from your sector and frameworks; the register then narrows to the rows your thresholds trigger.
The April 2026 Form PF proposal is the clearest example of why that matters. If it is adopted as proposed, the share of SEC-registered advisers that file Form PF falls from about 70% to about 40%. A manager with $600 million in private fund assets should be watching that release more closely than anyone.
| Obligation | Triggered by | Cadence |
|---|---|---|
| Compliance program, CCO, annual review | SEC registration (Rule 206(4)-7) | At least annually |
| Code of ethics, personal trading | SEC registration (Rule 204A-1) | Quarterly transactions, annual holdings |
| Custody, audited financials | Custody of client assets (Rule 206(4)-2) | Within 120 days of fiscal year end |
| Form PF | $150M private fund AUM today, $1.5B for quarterly hedge fund filing | Annual or quarterly, 72-hour current reports for large hedge fund advisers |
| Form 13F | $100M in 13(f) securities | 45 days after each quarter |
| Schedule 13D or 13G | More than 5% of a registered equity class | 13D in 5 business days; 13G 5 business days or 45 days after quarter end |
| CFTC exemption affirmation | Claiming Rule 4.13(a)(3) | Within 60 days of calendar year end |
| Regulation S-P program | SEC registration | In force; customer notice within 30 days of a breach |
The stack, honestly
Best hedge fund compliance software for each layer of the job
No single product covers a fund manager's whole compliance program. Here is what each layer does, who sells it, and the one layer we sell.
Rule change tracking and the annual review
ComplianceOfficer
Watches SEC, CFTC and FinCEN releases, keeps the filing calendar current, maps changes to your manual and logs the review. $149 a month, published.
Regulatory reporting
Fund administrators, Form PF and 13F tools
Builds the filings from portfolio and position data. Usually priced inside an administrator contract or quoted.
Employee compliance and code of ethics
StarCompliance, MyComplianceOffice, ComplySci
Brokerage feeds, pre-clearance, restricted lists, holdings and transaction reports. Quoted per covered person.
Communications archive and surveillance
Smarsh, Global Relay, Theta Lake
Captures email, chat, text and voice for books-and-records rules and reviews it. Platform fee plus per-user content fees.
What it costs
Hedge fund compliance software pricing from public lists and recorded contracts
Read on 2 October 2026. Marketplace figures are the vendor's own list prices; Vendr figures are contracts reported by buyers, not quotes.
| Vendor | Layer | Public price | Metered on |
|---|---|---|---|
| Theta Lake | Archive and surveillance | AWS Marketplace: SMB Platform (up to 999 users) $15,000 a year, Enterprise Platform $50,000 | Platform plus per user, per year content SKU |
| Smarsh | Archive and surveillance | AWS Marketplace: $25,000 annual minimum platform fee. Vendr median $22,759 | Platform plus per user, per content type |
| Global Relay | Archive and surveillance | Vendr median $6,793, range $975 to $7,800 | Per account, where every mailbox and phone number is an account |
| StarCompliance, MyComplianceOffice, ComplySci | Employee compliance | No list price; Vendr pages carry no recorded contracts | Quoted per covered person |
| Regology | Regulatory change | $1,700 per user per month on a 3-year contract (its pricing page) | Per user |
| ComplianceOfficer | Regulatory change and annual review | $149 a month or $894 a year | Flat, per firm |
Archive contracts are where a small manager overpays, because the meter counts channels and devices, not people. How the three archive vendors compare on contract terms is in Smarsh competitors and Global Relay pricing, and the Smarsh price list itself in Smarsh pricing. For regulatory change tools specifically, see regulatory change management software pricing.
Who uses it
Private equity compliance software and hedge fund compliance for lean teams
The COO who is also CCO
Common under $1 billion. The register tells you what changed this week in five minutes and keeps the year's dates straight.
Emerging managers
Newly registered advisers are an SEC exam priority for 2026. Walk in with a dated record of every review you did.
Private equity sponsors
The April 2026 proposal drops quarterly event reporting for PE advisers. Track whether it lands and when.
Outsourced CCO firms
One register per client fund manager, each scoped to its own thresholds, with the review log ready for the annual report.
Managers that also run separately managed accounts for retail clients will find the adviser-side rules on RIA compliance software. The adviser AML program, now due January 1, 2028, is covered on AML compliance software, and the wider sector on financial services compliance software.
Questions fund managers ask
What software do hedge funds use for compliance?
Usually four kinds, bought separately. A communications archive with surveillance (Smarsh, Global Relay, Theta Lake), an employee compliance tool for personal trading and the code of ethics (StarCompliance, MyComplianceOffice, ComplySci), a regulatory reporting tool or administrator for Form PF and 13F, and something that tracks which SEC and CFTC rules changed and what that means for the manual. ComplianceOfficer is the fourth kind, for $149 a month.
How much does hedge fund compliance software cost?
The archive is usually the biggest line. Theta Lake lists its SMB platform on AWS Marketplace at $15,000 a year before per-user content fees, Smarsh lists a $25,000 annual minimum platform fee, and Global Relay contracts on Vendr have a $6,793 median. Employee compliance tools are quoted per covered person. ComplianceOfficer publishes $149 a month or $894 a year.
What are the compliance requirements for hedge funds?
For an SEC-registered hedge fund adviser the core is a written compliance program reviewed every year with a named CCO (Rule 206(4)-7), a code of ethics with personal trading reports (Rule 204A-1), the custody rule (Rule 206(4)-2), the Marketing Rule, Form ADV and Form PF filings, 13F and 13G reporting once thresholds are crossed, Regulation S-P, and CFTC registration or an exemption if the fund trades futures or swaps.
Do hedge funds need a compliance officer?
An SEC-registered adviser must designate a chief compliance officer under Rule 206(4)-7, who administers the written policies and procedures. The rule does not require a full-time hire, and many smaller managers give the role to the COO or general counsel or outsource it to a consultant. Exempt reporting advisers are not subject to that rule, though they still file parts of Form ADV.
Who has to file Form PF?
Today, an SEC-registered adviser with at least $150 million in private fund assets under management files Form PF, and a large hedge fund adviser ($1.5 billion or more in hedge fund assets) files quarterly within 60 days of quarter end. An SEC and CFTC proposal from April 20, 2026 would raise the filing threshold to $1 billion and the large hedge fund adviser threshold to $10 billion.
When do the Form PF amendments take effect?
July 1, 2027, after a fourth extension. The amendments adopted in February 2024 were first due March 12, 2025, then June 12, 2025, October 1, 2025 and October 1, 2026. On August 31, 2026 the SEC and CFTC moved the date to July 1, 2027, partly so filers do not build for amendments the April 2026 proposal may remove.
Is the SEC private fund adviser rule still in effect?
No. The Fifth Circuit vacated the 2023 private fund adviser rules in June 2024, so the quarterly statement, mandatory audit and restricted activities rules never took effect. The underlying duties did not go away. Custody, the Marketing Rule, the compliance rule and fiduciary obligations still apply, and examiners still look at fees and expenses closely.
Find out about the next extension the week it is published
One register for your firm, watched daily, for $149 a month. How the watch works is on regulatory change management software, and the manual itself on policy management software.
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