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    Free Download · 2026 Edition

    The Missed Filing Recovery Kit

    Catch-up checklists for the five deadlines firms miss most — Form D and Blue Sky notices, Form N-CEN, NFA annual affirmations, LEI renewals, and FinCEN MSB registration.

    • Late Form D, annual amendment, and state Blue Sky notice catch-up
    • NT N-CEN extension timeline for registered funds
    • NFA exemption reinstatement and annual affirmation steps
    • Lapsed LEI renewal plus FinCEN MSB renewal and agent list

    Get the kit

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    What's inside

    5 sections, 30 line items — one for each filing type, each ending with next year's calendar date.

    1

    Section 1 — Late Form D and Blue Sky notices

    2

    Section 2 — NT N-CEN and late Form N-CEN

    3

    Section 3 — Lapsed NFA exemptions

    4

    Section 4 — Lapsed LEIs

    5

    Section 5 — FinCEN MSB registration renewal

    Missed a deadline? Most can still be fixed

    Public records like EDGAR, NFA BASIC, GLEIF and FinCEN's MSB search show when a filing is late or lapsed. That doesn't automatically mean a violation, but it is visible to banks, counterparties, allocators and regulators.

    This kit walks through each catch-up filing in order: confirm your status, file what's missing, fix related records, and put next year's date on the calendar.

    • Confirm your status in the public record before filing anything
    • Fix related documents (offering docs, Form ADV, entity records) at the same time
    • Talk to counsel about any activity during a lapse

    Built by working CCOs

    Compiled from live engagements across SEC-registered, state-registered, and exempt-reporting firms.

    2026-current

    Reflects the rules and guidance in effect for the 2026 examination cycle.

    Examiner-tested

    Organized around the deficiency themes regulators actually cite in exam letters.

    Frequently asked questions

    Can I still file a late Form D?

    Yes. EDGAR accepts late Form D filings, and most states accept late Blue Sky notices, often with a late fee.

    What happens if an NFA exemption isn't affirmed?

    It is treated as withdrawn. The fund may need to re-claim the exemption or register before trading commodity interests.

    Does FIN Group file these for clients?

    Yes. The Missed Deadline Rescue Bundle ($2,500 one-time) covers catch-up filings across Form D, NFA, LEI and FinCEN, plus 90 days of Filing & Renewal Autopilot.

    Want us to get you current?

    The Missed Deadline Rescue Bundle ($2,500 one-time) files the catch-up work across Form D, NFA, LEI and FinCEN, then tracks every renewal for 90 days on Filing & Renewal Autopilot.

    More free tools in the compliance resources hub.