A question on Form C-AR (Annual Report) filing requirements.
Let's say an issuer launches an offering in November 2023, and closes in January 2024. Assume that same issuer has a fiscal year-end of 12/31.
Are they required to file a Form C-AR in April 2024, or April 2025?
Essentially, does the "...no later than 120 days after the end of the fiscal year covered by the report" come in based on the year the offering first went live or the year the offering was closed?
If it's based on when they "sold securities", does that happen at the time an issuer makes a commitment and wires money, or when the offering closes and subscription docs are signed and dated?