Audit requirements
Last updated: December 18, 2025
Quick definition
Audit requirements are the mandatory independent examinations of a hedge fund's financial statements and operational controls that fund managers must comply with, typically conducted annually by an independent accounting firm following applicable accounting standards.
Audit requirements are mandatory financial examinations that hedge funds must undergo each year. An
Fund managers must hire qualified accounting firms to conduct these examinations. The auditor reviews financial statements, tests portfolio valuations, and examines operational controls. This independent verification helps investors trust that the fund accurately reports its activities and performance.
The SEC custody rule creates the main legal requirement for hedge fund audits. Fund managers can avoid stricter custody requirements if they deliver annual audited financial statements to each investor within 120 days of their fiscal year end.
This arrangement is called the "pooled vehicle annual audit exception." It allows managers to skip quarterly account statements from qualified custodians. Managers also avoid annual surprise examinations. However, managers must deliver financial statements with a clean audit opinion to maintain this regulatory benefit.
The timing requirement creates a direct connection between audit performance and regulatory compliance. When audits run late or receive qualified opinions, managers may lose their regulatory advantages. They then become subject to additional custody rule requirements.
The audit process involves comprehensive examination by qualified accounting firms that meet professional standards. The
Auditors must be registered with and subject to regular inspection by the Public Company Accounting Oversight Board. This requirement ensures that only qualified firms with proper oversight conduct hedge fund audits. Audits must be performed according to generally accepted auditing standards. Financial statements must be prepared in accordance with
Auditors examine financial statements and may also provide accounting and tax services. Together with
The audit typically includes random testing of ledger accounts and portfolio valuations. When auditors find irregularities, they conduct more rigorous investigations. Auditors may also advise funds on regulatory compliance and coordinate with fund lawyers on tax requirements. The fund pays the auditor's fees rather than the management company.
Registered hedge funds face much stricter audit and reporting requirements than private funds. They must provide audited annual reports and unaudited semi-annual reports to investors within 60 days of each period's end. These reports become public documents filed with the SEC. They must include detailed financial statements showing all portfolio holdings.
Registered funds must also comply with Sarbanes-Oxley certification requirements when filing these reports. This adds extra compliance layers and accountability to the audit process. Additionally, registered funds must appoint a chief compliance officer and adopt comprehensive compliance policies and procedures.
The enhanced oversight reflects the broader investor base and public nature of registered funds. This differs from private hedge funds that rely primarily on custody rule audit exceptions.
Audit requirements connect closely to broader custody and compliance duties that hedge fund managers must meet. The pooled vehicle annual audit exception creates a direct relationship between audit performance and custody rule compliance. This makes timely and accurate audits essential for operational efficiency.
Managers who miss audit delivery deadlines may still qualify for the exception under certain conditions. They must have reasonably believed the audited financial statements would arrive on time. The failure must be due to unforeseeable circumstances. This provides some flexibility while maintaining investor protections.
Beyond regulatory compliance, audit requirements have become key parts of operational
The audit process provides important assurance about the accuracy of performance reporting and asset valuations. These are critical for investor confidence and fund marketing activities. Independent auditors serve as crucial intermediaries in the investor-manager relationship. They provide objective verification of fund operations and financial reporting.
Audit requirements require close coordination between fund managers and their service providers. This includes fund administrators, prime brokers, and custodians. This coordination ensures that accurate and complete information is available for audit purposes. It also maintains proper segregation of duties and internal controls.
The integration of audit requirements with service provider relationships creates operational interdependencies that fund managers must carefully manage. This includes establishing information sharing protocols. Managers must maintain proper documentation standards and coordinate timing across multiple service providers to meet audit deadlines.
Fund audit committees, when present, play an important oversight role. They ensure audit quality and independence while managing relationships between management and external auditors.
The audit requirements framework operates within the existing custody rule structure established under
Fund managers must stay current with evolving requirements to maintain compliance. They must ensure their audit processes remain aligned with regulatory expectations. This includes monitoring guidance from the SEC and other regulatory bodies. Managers should also stay informed about industry best practices and emerging audit standards.
The SEC continues to examine audit-related compliance through regular inspections. The agency has issued guidance on emerging areas such as digital asset custody and valuation, cybersecurity considerations, and the application of audit requirements to complex investment structures. These developments require ongoing attention from fund managers to ensure their audit programs address current regulatory priorities.
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