SEC Adopts Additional Amendments to Form PF

February 12, 2024

What happened? 

On February 8, 2024, the SEC adopted additional amendments to Form PF that build on those adopted in May and July of 2023. The amendments will require SEC-registered advisers to private funds, particularly advisers to hedge funds, to report additional information on Form PF. The amendments’ effective and compliance dates will be one year after their publication in the federal register.

According to the SEC’s Fact Sheet, the amendments to Form PF will introduce the following requirements, among others:

• Enhanced Reporting by Hedge Fund Advisers.

Advisers to hedge funds. Advisers to hedge funds will be required to report additional information on Form PF, including on:

• Investment strategies,
• Counterparty exposures, and
• Trading and clearing mechanisms.

Large hedge fund advisers. Large hedge fund advisers will need to report additional information regarding their qualifying hedge funds (defined as hedge funds with a net asset value of at least $500 million) on Form PF, including on:

• Investment exposures,
• Borrowing and counterparty exposure,
• Market factor effects,
• Currency exposure,
• Turnover,
• Country and industry exposure,
• Central clearing counterparty reporting,
• Risk metrics,
• Investment performance by strategy,
• Portfolio liquidity, and
• Financing and investor liquidity.

In addition, the amendments will remove the aggregate reporting requirement for large hedge fund advisers.

• Amended Reporting Requirements Regarding Complex Structures.

All Form PF Filers. Advisers must report separately on each component fund within master-feeder arrangements and parallel funds structures. Additionally, advisers must identify and report (on an aggregate basis) on trading vehicles used by reporting funds.

• Enhanced Reporting on Basic Information about Advisers and their Private Funds.

All Form PF Filers. All advisers filing Form PF will need to report additional information, including (but not limited to) the following topics:

• Assets under management,
• Withdrawal and redemption rights,
• Base currency,
• Borrowings and types of creditors,
• Fair value hierarchy,
• Beneficial ownership, and
• Fund performance.

What does this mean for me?

Form PF filers will need to prepare for compliance with these amendments to Form PF, along with additional amendments adopted in May and July of 2023. Advisers impacted by these amendments should consider updating their policies and procedures ahead of the compliance date, reviewing current operations to ensure that required data is available, and training employees on the new amendments.

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