Vertical guide · Updated June 2026
Registered investment company attorney time tracking: Form N-CEN annual report advisory, SEC EXAM fund examination advisory, and proxy statement annual meeting advisory
Registered investment company attorneys advising mutual funds, exchange-traded funds, closed-end funds, and business development companies under the Investment Company Act of 1940 — including Form N-CEN annual reporting obligations under ICA Rule 30a-1, 17 C.F.R. § 270.30a-1, advisory agreement approval and assignment obligations under ICA §§ 15(a) and 15(b), board independence requirements under ICA § 10, and the annual § 15(c) advisory fee reasonableness review — whose time records must satisfy the registered investment company legal advisory documentation standard and the lodestar arithmetic required when EXAM examination findings escalate to SEC enforcement proceedings against the fund's investment adviser — generate three billing gaps driven by the concentrated January–March Form N-CEN filing deadline window, the unpredictable SEC EXAM fund examination initiation calendar, and the fund's fixed annual meeting calendar: Form N-CEN annual report advisory calls on the SEC filing deadline calendar (4 fund clients × 3 calls × 45 min × 55% untracked ≈ 4.9 hrs = $2,205–$3,675/year at $450–$750/hr), SEC EXAM fund examination advisory calls on EXAM's examination scheduling calendar (3 clients × 4 calls × 50 min × 55% ≈ 5.5 hrs = $2,475–$4,125/year at $450–$675/hr), and proxy statement and annual meeting advisory calls on the fund's annual meeting calendar (5 clients × 3 calls × 40 min × 55% ≈ 5.5 hrs = $2,475–$4,125/year at $450–$675/hr). For a registered investment company solo practice, the annual billing gap is $7,155–$11,925.
TL;DR
ClaimHour captures every Form N-CEN completeness and service provider agreement compliance advisory call that arrives in the concentrated January–March annual report filing window, every SEC EXAM Initial Information Request receipt and fund examination response advisory call that arrives on EXAM's unannounced examination scheduling calendar, and every proxy statement disclosure review and ICA § 15(c) advisory fee reasonableness review advisory call that arrives on the fund's annual meeting calendar — passively, no timer, no audio, no call contents. $29–$59/mo. No PMS required.
Form N-CEN annual report advisory: calls on the SEC filing deadline calendar
Registered investment companies — including open-end management investment companies (mutual funds), exchange-traded funds registered as open-end investment companies, closed-end management investment companies, unit investment trusts, and business development companies registered as closed-end funds — must file their annual report to the SEC on Form N-CEN within 75 days of the fund's fiscal year end under Investment Company Act Rule 30a-1, 17 C.F.R. § 270.30a-1. Form N-CEN replaced Form N-SAR for most registered investment companies beginning with fiscal years ending on or after June 1, 2018, under SEC Release IC-33142. The Form N-CEN is a structured data submission that requires registered investment companies to report five categories of information: (Part A) Identification information; (Part B) Information about the fund's management investment company characteristics; (Part C) Additional operational information including the fund's principal underwriter, transfer agent, securities lending program, liquidity risk management program, and derivatives risk management program; (Part D) Information specific to exchange-traded funds; and (Part E) Signatures. Because most mutual funds and ETFs use December 31 fiscal year ends — reflecting the calendar-year organization of their investment advisers and the convenience of annual reporting for calendar-year investor tax reporting — the Form N-CEN deadline concentrates at March 16 for calendar-year fund clients, creating a concurrent advisory call burden for all calendar-year fund clients in the same January–March window.
Three Form N-CEN annual report advisory call types that arrive on the SEC filing deadline calendar: (1) Form N-CEN completeness and accuracy advisory call — arrives in January–February when outside fund counsel must advise on the fund's responses to Form N-CEN's reporting items, including the fund's identification of all series (sub-fund) information under Part A (including the fund's CIK number and the series' LEI, net assets, and shares outstanding as of fiscal year end), the fund's operational information under Part B (including the fund's investment adviser, any sub-advisers, the fund's principal underwriter, and any changes in the fund's service provider arrangements during the fiscal year), the fund's material events under Part C's Item C.7 (including any material changes to the fund's investment objective, policies, or restrictions during the fiscal year that required shareholder approval under ICA § 13(a), any changes in the fund's principal underwriter, transfer agent, or custodian, and any litigation or regulatory actions involving the fund or its investment adviser during the fiscal year), and the fund's derivatives risk management program information under Part C's Item C.11 (which requires funds that use derivatives to report whether they have adopted a derivatives risk management program under Rule 18f-4 or rely on the limited derivatives user exception) (42–50 min) — arriving in the January–March window for calendar-year funds; (2) fund service provider agreement compliance advisory call — arrives concurrently with the Form N-CEN review when outside fund counsel must review the fund's investment advisory agreement for compliance with ICA § 15(a) (which requires that the advisory agreement provide for automatic termination in the event of its assignment), the fund's underwriting agreement for compliance with ICA § 15(b) (which limits the fund's principal underwriting arrangements to registered broker-dealers), and the fund's custody agreement for compliance with ICA Rule 17f-2 (which requires the fund to maintain assets with a qualified custodian) — confirming that all service provider agreements currently in effect were approved by the fund's board and shareholders in accordance with ICA §§ 10, 15(a), and 15(c)'s approval requirements (42–50 min); (3) Form N-PORT concurrent filing review and coordination advisory call — arrives in January–March when outside fund counsel must review the fund's concurrent Form N-PORT filings for the quarter ending December 31 (which are due within 30 days of fiscal quarter end under Rule 30b1-9 for large fund groups with more than $1 billion in net assets) for consistency with the fund's Form N-CEN annual report disclosures, and advise on whether any discrepancies between the monthly Form N-PORT portfolio holdings data and the annual Form N-CEN operational disclosures require amendment of a prior Form N-PORT filing under Rule 30b1-9(b) (42–50 min). At 55% untracked: 4 clients × 3 calls × 45 min × 55% = 297 min / 60 ≈ 4.9 hours = $2,205–$3,675/year at $450–$750/hr.
SEC EXAM fund examination advisory: calls on EXAM's examination scheduling calendar
The SEC Office of Examinations conducts examinations of registered investment companies — including mutual funds, ETFs, closed-end funds, and business development companies — under Investment Company Act § 31(b), 15 U.S.C. § 80a-30(b), which grants the SEC authority to examine the books, accounts, and records of any registered investment company at any time. EXAM conducts fund examinations on its own risk-based scheduling calendar, prioritizing funds for examination based on the fund's size (net assets and number of shareholders), the time since the fund's last examination, the complexity of the fund's investment strategies (including derivatives usage, alternative investment strategies, and leverage), investor complaints filed with the SEC about the fund, and referrals from the SEC's Division of Enforcement or Division of Investment Management. Because EXAM's examination selection is risk-based and confidential, registered investment company attorneys cannot anticipate or plan for the initiation of an examination — the IIR letter arrives without prior notice, requiring the fund's board of directors to immediately engage outside fund counsel to coordinate the production response and advise on the examination process. EXAM fund examinations typically focus on the fund's compliance with the Investment Company Act's core provisions: advisory fee approval (ICA § 15(a) and § 15(c)), affiliated transaction restrictions (ICA § 17), valuation and pricing (ICA Rule 2a-4), leverage limitations (ICA § 18), securities lending (ICA § 17(a)(3)), custody (ICA Rule 17f-2), and the fund's ICA Rule 38a-1 compliance program.
Four SEC EXAM fund examination advisory call types that arrive on EXAM's examination scheduling calendar: (1) EXAM Initial Information Request receipt and fund production coordination advisory call — arrives when EXAM issues the IIR letter to the fund's board of directors or its designated contact, when outside fund counsel must advise on the scope of the IIR's document production requests for fund records (including board minutes, advisory agreement approval documentation, affiliated transaction approvals, securities lending program records, and custody reconciliation records), the assertion of attorney-client privilege over communications between outside fund counsel and the fund's board in the preparation of the examination response, the negotiation of the IIR's production deadline with EXAM staff, and the fund's document preservation obligations during the EXAM examination (46–56 min) — arriving without advance notice on EXAM's examination initiation calendar; (2) EXAM on-site examination and board interview preparation advisory call — arrives when EXAM staff schedules the on-site examination, when outside fund counsel must prepare the fund's chief compliance officer and independent directors for EXAM staff interviews (advising on the scope of EXAM's authority to interview the fund's independent directors about the § 15(c) advisory fee approval process, the § 17 affiliated transaction approval records, and the fund's ICA Rule 38a-1 compliance program annual review documentation), and advise on the board's real-time response obligations when EXAM staff requests additional documents during the on-site visit (46–56 min); (3) EXAM deficiency letter response and board disclosure advisory call — arrives when EXAM issues a deficiency letter identifying areas of concern in the fund's compliance with the Investment Company Act, when outside fund counsel must advise on the fund board's obligation to respond to EXAM's deficiency letter with a corrective action plan, the board's disclosure obligation to fund shareholders if the EXAM deficiency relates to a matter material to the fund's investment adviser's management of the fund, and whether EXAM's deficiency findings create a disclosure obligation in the fund's next Form N-CEN annual report under Part C's Item C.7 material event disclosure (46–56 min); (4) EXAM escalation and enforcement referral advisory call — arrives when EXAM staff indicates that examination findings may be referred to the SEC's Division of Enforcement, when outside fund counsel must advise the fund's board on the scope of the board's independent obligations under ICA § 10's independent director requirements and Regulation S-X Rule 17 CFR 210.6-25 if the fund's investment adviser faces an SEC enforcement proceeding arising from the fund examination, including the board's obligation to retain independent counsel separate from the investment adviser's counsel in any enforcement proceeding that creates a conflict between the fund's interests and the investment adviser's interests (46–56 min). At 55% untracked: 3 clients × 4 calls × 50 min × 55% = 330 min / 60 ≈ 5.5 hours = $2,475–$4,125/year at $450–$675/hr.
Proxy statement and annual meeting advisory: calls on the fund's annual meeting calendar
Registered investment companies that are organized as corporations or business trusts with annual shareholder meeting requirements — including most closed-end management investment companies and many open-end mutual funds that hold annual shareholder meetings for the election of directors — must file proxy statements with the SEC and distribute them to shareholders under Exchange Act § 14(a) and SEC Regulation 14A, 17 C.F.R. § 240.14a-1 through 240.14a-21. The fund's annual meeting calendar is set by the fund's board of directors, subject to the fund's organizational documents and any state law annual meeting requirements, and the proxy statement filing deadline (at least 40 days before the annual meeting for proxy statements filed under the notice and access rules of Exchange Act Rule 14a-16) is established by counting back from the annual meeting date set by the board. Because the fund's annual meeting date is set by the board on an annual cycle that is not coordinated with outside fund counsel's billing schedule, proxy statement advisory calls arrive on the fund's annual meeting calendar — typically in the spring (March–June) for funds with December 31 fiscal year ends — creating a billing gap that arrives concurrently with the Form N-CEN annual report advisory calls in January–March.
Three proxy statement and annual meeting advisory call types that arrive on the fund's annual meeting calendar: (1) proxy statement disclosure review and fund governance advisory call — arrives in February–April when outside fund counsel must review the preliminary proxy statement (or draft proxy statement) for compliance with Schedule 14A's requirements for investment company proxy statements, including the disclosure of the fund's nominee directors' independence status under ICA § 10(d) and the definition of "interested person" under ICA § 2(a)(19) (which requires that at least 40% of the fund's board consist of persons who are not "interested persons" of the fund or its investment adviser), the disclosure of the fund's audit committee's composition and the audit committee's financial expert under Sarbanes-Oxley § 407 (which requires registered investment companies to disclose whether the audit committee includes a financial expert), the disclosure of the investment adviser's compensation arrangements including performance fees and any departure from the standard advisory fee schedule, and the disclosure of any material conflicts of interest between the independent directors and the fund's investment adviser under ICA § 36 (38–44 min) — arriving on the fund's annual meeting preparation calendar; (2) annual meeting proposal and ICA § 15(a) advisory agreement approval advisory call — arrives when the fund's proxy statement includes a proposal for shareholder approval of the investment advisory agreement under ICA § 15(a), the continuance of an existing advisory agreement under ICA § 15(a)'s requirement for annual approval by the fund's board (including a majority of the independent directors) or by a shareholder vote, or the approval of a new advisory agreement following an assignment of the existing advisory agreement under ICA § 15(a)'s automatic termination on assignment provision — when outside fund counsel must advise on the materiality of the changes in the advisory agreement requiring shareholder approval, the proxy statement's description of the reasons for the board's approval recommendation under the § 15(c) advisory fee reasonableness factors, and the required vote threshold for the shareholder approval under ICA § 12(b) (majority of the fund's outstanding voting securities, defined as the lesser of 67% of shares present at the meeting if more than 50% are present, or more than 50% of all outstanding shares) (38–44 min); (3) ICA § 15(c) advisory fee reasonableness annual review advisory call — arrives annually when the fund's board conducts its annual renewal of the investment advisory agreement under ICA § 15(c), which requires the fund's board to request from the investment adviser — and the investment adviser to provide — the information reasonably necessary to evaluate the terms of the advisory contract, including the advisory fee reasonableness factors identified in Gartenberg v. Merrill Lynch Asset Management, Inc., 694 F.2d 923 (2d Cir. 1982): (i) the nature, extent, and quality of services provided; (ii) the investment performance of the fund and the adviser; (iii) the costs of the services to be provided and profits realized by the adviser; (iv) the extent to which the adviser realizes economies of scale as the fund grows; (v) the existence of fall-out benefits from the advisory relationship; and (vi) comparative fee information — and when outside fund counsel must advise on the board's process for receiving and evaluating the § 15(c) information package, the independent directors' obligation to engage in a deliberative process demonstrating their awareness of all factors relevant to the advisory fee evaluation under the Jones v. Harris Associates L.P. standard, and the board minutes' documentation of the § 15(c) approval deliberations (38–44 min). At 55% untracked: 5 clients × 3 calls × 40 min × 55% = 330 min / 60 ≈ 5.5 hours = $2,475–$4,125/year at $450–$675/hr.
How ClaimHour fits registered investment company practice
If you advise registered investment companies on Form N-CEN annual reporting with completeness and service provider agreement advisory calls clustering in the concentrated January–March SEC filing deadline window, prepare fund boards for SEC EXAM examinations with IIR production advisory calls and deficiency letter response advisory calls arriving on EXAM's unannounced scheduling calendar, and conduct proxy statement disclosure reviews and ICA § 15(c) advisory fee reasonableness annual review advisory calls arriving on the fund's annual meeting calendar — and your invoices consistently understate the Form N-PORT concurrent filing review advisory calls that arrive simultaneously with the Form N-CEN advisory in January–March, the EXAM on-site board interview preparation advisory calls that arrive on EXAM's examination scheduling calendar, and the ICA § 15(c) annual review information package evaluation advisory calls that arrive on the fund board's annual contract renewal calendar — ClaimHour was built for that gap.
Related questions
How do Form N-CEN annual report advisory calls generate billing gaps on the SEC filing deadline calendar?
All calendar-year fund clients face the same March 16 Form N-CEN deadline simultaneously under ICA Rule 30a-1, concentrating advisory calls from all calendar-year fund clients in the same January–March window. Three call types: Form N-CEN completeness and accuracy advisory (42–50 min), fund service provider agreement compliance advisory (42–50 min), and Form N-PORT concurrent filing coordination advisory (42–50 min). At 55% untracked: 4 clients × 3 calls × 45 min × 55% ≈ 4.9 hours = $2,205–$3,675/year at $450–$750/hr.
How do SEC EXAM fund examination advisory calls generate billing gaps on EXAM's examination scheduling calendar?
EXAM initiates fund examinations on its risk-based scheduling calendar with no advance notice to outside fund counsel — the IIR letter arrives without warning, requiring immediate production coordination. Four call types: EXAM IIR receipt and fund production coordination advisory (46–56 min), EXAM on-site examination and board interview preparation advisory (46–56 min), EXAM deficiency letter response and board disclosure advisory (46–56 min), and EXAM escalation and enforcement referral advisory (46–56 min). At 55% untracked: 3 clients × 4 calls × 50 min × 55% ≈ 5.5 hours = $2,475–$4,125/year at $450–$675/hr.
How do proxy statement and annual meeting advisory calls generate billing gaps on the fund's annual meeting calendar?
The fund's board sets the annual meeting date on the fund's organizational calendar — not coordinated with outside counsel's billing schedule — with proxy statement filing and distribution deadlines established by Regulation 14A's 40-day advance notice requirement. Three call types: proxy statement disclosure review and fund governance advisory (38–44 min), annual meeting proposal and ICA § 15(a) advisory agreement approval advisory (38–44 min), and ICA § 15(c) advisory fee reasonableness annual review advisory (38–44 min). At 55% untracked: 5 clients × 3 calls × 40 min × 55% ≈ 5.5 hours = $2,475–$4,125/year at $450–$675/hr.
How does registered investment company attorney billing differ from investment adviser compliance attorney billing?
Registered investment company attorney billing centers on fund-entity obligations: Form N-CEN annual report advisory clustering in January–March (4.9 hours = $2,205–$3,675/year), SEC EXAM fund examination advisory arriving on EXAM's scheduling calendar (5.5 hours = $2,475–$4,125/year), and proxy statement and ICA § 15(c) annual meeting advisory on the fund's annual meeting calendar (5.5 hours = $2,475–$4,125/year). Investment adviser compliance attorney billing centers on the fund's registered investment adviser's individual compliance obligations: Form ADV annual update advisory clustering in February–March, SEC EXAM examination advisory arriving on EXAM's scheduling calendar, and Rule 206(4)-7 compliance program annual review advisory clustering in October–December. Combined registered investment company annual billing gap: 4.9 + 5.5 + 5.5 = 15.9 hours = $7,155–$11,925/year.
Further reading
- Investment adviser compliance attorney time tracking — SEC Form ADV annual update advisory, SEC EXAM examination preparation advisory, and IAA Rule 206(4)-7 compliance program annual review advisory billing gaps; relevant for registered investment company attorneys whose fund clients' registered investment advisers generate concurrent Form ADV annual update advisory calls in the same January–March window as the fund's Form N-CEN annual report advisory calls
- Hedge fund attorney time tracking — SEC Form ADV annual amendment advisory, IAA § 206 enforcement advisory, and Form 13F quarterly reporting advisory billing gaps; relevant for registered investment company attorneys whose practice extends from registered fund compliance to private fund adviser compliance under the IAA's requirements for both registered investment companies and exempt reporting advisers
- Securities enforcement defense attorney time tracking — SEC Wells Notice response advisory, SEC administrative proceedings hearing preparation advisory, and FINRA enforcement proceeding advisory billing gaps; relevant for registered investment company attorneys whose fund clients' investment advisers escalate from EXAM fund examination to SEC Division of Enforcement investigation and Wells Notice proceedings based on EXAM findings
- Public company disclosure attorney time tracking — Form 10-K annual report advisory, Form 10-Q quarterly report advisory, and Form 8-K material event advisory billing gaps; relevant for registered investment company attorneys whose closed-end fund clients are also Exchange Act reporting companies subject to annual Form 10-K, quarterly Form 10-Q, and event-driven Form 8-K reporting obligations in addition to the Investment Company Act's Form N-CEN annual reporting obligations
- Shareholder derivative attorney time tracking — pre-suit investigation and demand advisory, special litigation committee investigation advisory, and settlement approval advisory billing gaps; relevant for registered investment company attorneys whose fund clients face shareholder derivative litigation under ICA § 36(b) alleging that the fund's investment advisory fees are excessive and constitute a breach of fiduciary duty by the investment adviser
- Investment adviser compliance attorney fee petition mechanics — long-form companion covering SEC EXAM examination timeline billing gaps and the EAJA § 504 fee-shifting framework applicable when EXAM findings against the fund's investment adviser escalate to SEC administrative proceedings where the adviser prevails and the Enforcement Division's position was not substantially justified under Pierce v. Underwood, 487 U.S. 552