Although IARD/PFRD is scheduled to be available Saturday the 30th, we recommend filing be completed by April 29th
If you are an SEC registered investment adviser and manage private funds, you must file a Form PF if you had at least $150 million in private fund assets under management as of the end of your most recently completed fiscal year. All private fund advisers must complete Section 1 of Form PF at least annually, within 120 days of the firm’s fiscal year-end (April 30th for firms with a fiscal year end of December 31st). Large private fund advisers may be required to provide additional data in Sections 2, 3 and 4. Additionally, large hedge fund advisers and large liquidity fund advisers must file every quarter, 60 days after the end of each quarter.
Organizing the large amount of data necessary to file Form PF will take the most effort. For private fund advisers that are not filing Form PF quarterly, regulatory assets under management (“RAUM”) should be measured at the end of the adviser’s most recent fiscal year. Large hedge fund advisers should measure RAUM as of the last day of any month in the preceding fiscal quarter. Note that amounts should be consistent across Form PF, Form ADV filings, other regulatory documents and marketing materials for a fund.
- Work with your partners, fund administrators, brokers and custodians to obtain the required data.
- Document decisions on data, such as your valuation methodology. Having a system for collecting and organizing internal data for all documentation ensures consistency.
- Organize data to meet recordkeeping requirements and to maintain your records and support the valuation methodology.
- Make use of the published instructions and FAQ (linked below) to navigate questions around estimates, audited financial statements and other scenarios.
Watch Out for Common Mistakes
Once the data is organized and a draft is prepared, be on the look-out for common mistakes.
- Make sure you have a balance of at least $150 in your IARD account to cover the filing fee, otherwise the filing will not be accepted.
- Review private fund identification numbers for each fund. These are generated/displayed on the Form ADV 1 (Item 7.B of Schedule D).
- If you need to add additional private funds, it may be necessary to file an other-than-annual ADV amendment to generate identification numbers for the new funds.
- Once generated for a private fund, the same private fund identification number must be used to identify that private fund on all subsequent filings such as Form PF.
- Make one last comparison of the valuations and data in Form PF against those reported on Form ADV and maintain your records supporting these figures.
There is still time for careful review. The published instructions and FAQ are helpful resources as you prepare your Form PF.
The instructions to Form PF can be found here:
Form PF Frequently Ask Questions can be found here: https://www.sec.gov/divisions/investment/pfrd/pfrdfaq.shtml
Fairview Investment Services provides comprehensive and ongoing compliance services, including assistance with regulatory filings. Contact Fairview Investment Services with questions concerning Form PF and for additional information on creating a compliance program as a private fund adviser.