Form PF (private fund) is an SEC rule requiring private fund advisers to report regulatory assets under management to the Financial Stability Oversight Council (FSOC), an organization established under the Dodd-Frank Act in 2010 to monitor risks within the financial sector.

When and why did the SEC start requiring Form PF?

The SEC began requiring Form PF with the passage of the Dodd-Frank Act (see section 404 and 406). Dodd-Frank, signed into law by former President Obama, was created in response to the 2008 financial crisis and was designed to reduce the excessive risk-taking that led to the crisis. The first filing of Form PF was in 2012.

How has the SEC recently amended Form PF?

In March 2024, the SEC published new requirements to Form PF that will apply to submissions starting one year later, in March 2025. This amendment requires investment managers to disclose substantially more information than previously, such as:

  • For large hedge funds: Requests more insights on reporting exposure, borrowings, risk metrics, liquidity etc. Removes aggregate reporting.
  • For large and small hedge funds: Adds more detail about strategies, exposure, trading and clearing mechanics.
  • For investment managers with complex structures: Requires separate reporting for master feeder arrangements and parallel fund structures. Requires identification of trading vehicles and to report them on an aggregate basis.

This latest amendment follows two more limited-scope amendments announced in 2023:

  • An amendment published in June 2023 requires large hedge funds to file a report as soon as possible, but no later than 72 hours, after the occurrence of any one of several specified triggering events. Additionally, the amendment requires private equity adviser to file a report within 60 days of quarter end, after the occurrence of any one of several specified triggering events.
  • An amendment published in August 2023 requires certain “large liquidity provider” funds to provide more detail about their investment portfolios.

Who is required to file a Form PF?

All investment advisers, commodity pool operators and commodity trading advisers (CTAs) registered with the SEC with at least $150 million in private funds under management must periodically file Form PF. Private funds with assets under $150 million are not required to file.

Where do I access Form PF and how is it filed?

You must file Form PF electronically through the Form PF filing system on the Investment Adviser Registration Depository website‡, which contains detailed filing instructions.

Is Form PF filed annual or quarterly?

It is most often an annual filing, though there are a few exceptions. Some filers must do so quarterly, such as large hedge fund advisers, or those with hedge fund regulatory assets under management that exceed $1.5 billion, and large private equity fund advisers whose private equity regulatory assets under management exceed $2 billion.

Annual filings are due 120 days after year-end. Quarterly filings are due 60 days after quarter end.

How much does it cost to file Form PF?

The fee charged on the Investment Adviser Registration Depository website is $150 per filing. You must have at least $150 in your account before you can successfully file.

How much preparation does Form PF require?

While the SEC does not offer an estimated preparation time, it is generally best to start early. Preparation often requires gathering information from multiple sources such as your private fund administrator, investor relations group and your portfolio manager, which can take time.

Can I outsource Form PF to a third party?

A third party can definitely help file Form PF. For example, UMB Fund Services, a fund administrator, has several data feeds which populate a third-party browser-based software solution. UMB ensures the data populates the forms properly and also rolls forward any static data. The adviser then reviews the data and adds anything missing. The software runs validation checks to ensure a successful filing prior to the adviser electronically filing.

What information is required in Form PF?

Filing Form PF requires basic information about the adviser, any related persons, assets under management, etc. It also asks for information about each private fund including asset values, borrowings, investor classifications, performance, strategy, counterparties and trading style. Large hedge fund advisers will need to provide additional information about the portfolio such as asset types, exposure, turnover, and geography.

Learn more about how UMB can support your firm’s registered and alternative investment fund administration needs, or contact us to be connected with a fund services team member.

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