All PF Form submissions are submitted through the Private Fund Reporting Depository („PFRD”), which is part of the IARD online filing system. The P&C system charges a fee of $150 for all PF form submissions. Form PF is a regulatory reporting requirement that requires hedge fund managers (who are registered with the SEC) to regularly file a FORM PF with at least $150 million under management. Depending on the size of the assets under management of the managers, they must be submitted quarterly or annually. In this case, assets under management are defined as „regulatory assets under management (RAuM)”, which are in fact gross assets without deduction for short selling, lending or other forms of leverage. „It is very likely that the SEC will request data not only from Form PF, but also from Form CPO-PQR, which will be submitted to the National Futures Association (NFA), a self-regulatory authority, and then to the Commodity Futures Trading Commission (CFTC), as well as Annex IV reports submitted to European regulators under the Alternative Investment Fund Managers Directive (AIFMD). This is despite growing concern in Europe about safety and the purposes for which US regulators use European data. The SEC may even request to review the data disclosed to investors through an Open Protocol for Risk Aggregation („Open Protocol”, formerly known as OPERA), the risk reporting toolkit developed by Albourne Partners. Form PF was passed by the SEC following the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act („Dodd-Frank Act”).

„The Dodd-Frank Act amended section 204(b) of the Advisers Act of 1940 to require the SEC to establish reporting and record-keeping requirements for private fund advisors.” The SEC has adopted Form PF „to obtain data that facilitates the oversight of systemic risk in U.S. financial markets.” Form PF covers all private funds, including private equity funds, hedge funds and liquidity funds. The requirement for private fund advisors to file a Form PF stems from the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and has been in effect since July 2012. While none of the information reported on Form PF is made public, Form PF is an important information-gathering tool for the SEC as it helps the SEC monitor industry trends and inform rule-making. In particular, the information on Form PF shall inform the SEC of the amount of assets managed by private funds, the strategies and performance of private fund advisors, compliance risks and potential targets for audits and enforcement actions. Form PF is a regulatory filing requirement of the U.S. Securities and Exchange Commission that requires private fund advisors to report assets under management to the Financial Stability Supervisory Board in order to monitor risks to the U.S. financial system. Form PF affects SEC-registered managers of private equity funds, real estate funds, hedge funds, and liquidity funds with private fund assets of at least $150 million. For more information on Form PF, please visit the SEC website.

The SEC also has its own FAQ for form PF. For investment advisors and businesses that are currently registering as investment advisors in 2012, form PF has a two-step registration period. Form PF is a report that certain private fund advisors are required to file with the SEC under Rule 204(b)(a). A hedge fund and/or private equity advisor who held more than $150 million in regulatory assets at the end of the last completed fiscal year must file Form PF each year. An advisor who exclusively advises private equity funds and manages at least $2 billion in regulatory assets must file form PF and additional detailed information on a quarterly basis. An advisor who exclusively advises hedge funds and has at least $1.5 billion in regulatory assets must do the same. Here are some frequently asked questions about registering Form PF with the U.S. Securities and Exchange Commission („SEC”).

The information presented herein is of a general nature and does not replace the advice of an investment compliance professional regarding the requirements of the SEC and your personal circumstances. This website is not intended as a complete analysis of Form PF requirements and you should not rely solely on its content. Large hedge fund advisors must submit an updated Pf form within 60 calendar days of the end of their first, second and third financial quarters. You must submit a quarterly update that addresses all points on form PF regarding advised hedge funds. Within 60 calendar days of the end of their fourth fiscal quarter, large hedge fund advisors must submit a quarterly update to the PF form, which updates responses to all items. However, large hedge fund advisors may file an initial bid for the fourth quarter, updating information relating only to the hedge funds they advise, provided they amend the PF form within 120 calendar days of the end of the quarter to update information on the other private funds they advise. When leading hedge fund advisors file such a change, they are not required to update previously filed information for that quarter. For advisors whose assets under management are attributable to hedge funds of at least $5 billion, combined assets under management of at least $5 billion attributable to liquidity funds and registered money market funds, or advisors whose assets under management are attributable to private equity funds, the compliance date is June 15, 2012.

These entities must begin filing Form PF after the end of their first fiscal year or fiscal quarter to end on or after June 15, 2012. Large private fund advisors, on the other hand, need to report more information more frequently depending on the type of fund they oversee. .