News

Joint SEC-CFTC proposal would overhaul Form PF reporting

22 August 2022

The U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) proposed joint amendments to Form PF, a confidential reporting form required of certain SEC-registered investment advisers (RIAs) to private funds, on Wednesday, 10 August 2022. The amendments would enhance reporting requirements for all private fund advisers, hedge fund advisers in particular, and are designed to refine the federal government’s ability to monitor systemic risk from private funds, including the use of leverage.

The proposed amendments, in short:

enhance reporting of basic information about all advisers and the private funds they advise;
clarify how all advisers should report complex structures, such as master-feeder and parallel fund structures;
enhance reporting by large hedge fund advisers on “qualifying hedge funds” (i.e. those hedge funds with a net asset value of at least US$500 million);
enhance additional reporting about all hedge funds, generally; and
remove aggregate reporting for large hedge fund advisers.

The proposed amendments are available in full here, which includes a full draft amended version of Form PF. The public comment period will remain open through the later of (i) 60 days following publication of the proposing release on the SEC’s website (i.e. 11 October 2022) or (ii) 30 days following publication of the proposing release in the Federal Register, whichever period is longer.