SEC Form PF: What You Need to Know Now
Articles by: Richey May, Feb 09, 2022
For the first time in 10 years, the Securities and Exchange Commission has proposed amendments to Form PF, the reporting form for all SEC-registered hedge fund and private equity fund advisors who run funds of $2 billion or more.
Why this matters and what you need to know
Two things: The amendments would tighten filing requirements and decrease the reporting threshold. If the amendments pass, many registered investment advisors (RIAs) who manage large funds will need to complete these new filing requirements to remain compliant.
Why large funds and why now?
The growth and increasing complexity of the private fund industry is one reason. The other has to do with the analytics gleaned from scrutiny by the SEC and the Financial Stability Oversight Council since they introduced Form PF in 2011.
“The Commission and Financial Stability Oversight Council now have almost a decade of experience analyzing the information collected on Form PF,” said SEC Chair Gary Gensler, who noted “situations where we would benefit from additional information.”
Gensler explained that the proposal would require large fund advisers to report events “such as extraordinary investment losses or significant margin and counterparty default events.”
In those cases, the proposal would require large fund advisers to file reports within one business day. It would also lower the reporting threshold from $2 billion to $1.5 billion in assets under management.
How to prepare
At Richey May, we want to ensure our clients stay ahead of any changes in the industry. Our advice: Consult your legal counsel as soon as possible to see if you fall under the new requirement guidelines and, if so, how they could impact you. Our goal, as always, is to help you succeed at your business.