Form PF changes could impact reporting for investment advisers to private funds

The SEC and the Commodity Futures Trading Commission (CFTC) — collectively, the Commissions — jointly adopted amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, on Feb. 8, 2024.

Form PF was adopted in 2011, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. It provides the Commissions and Financial Statement Oversight Council (FSOC) with important information about the basic operations and strategies of private funds and their advisers and has helped establish a baseline picture of the private fund industry for use in assessing systemic risk.

Specific amendments will apply to all Form PF filers and require collection of additional identifying information about their managed private funds. Additional amendments apply specifically to advisers of hedge funds as well as those that advise qualifying hedge funds. Explore how your reporting requirements may be impacted below.

Amendment impacts

As stated by the SEC, the amendments will:

• Enhance reporting by large hedge fund advisers regarding qualifying hedge funds to provide better insight into the operations and strategies of these funds and their advisers and to improve data quality and comparability
• Enhance reporting of hedge funds to provide greater insight into hedge funds’ operations and strategies, to assist in identifying trends, and to improve data quality and comparability
• Amend how advisers report complex structures to improve the ability of the FSOC to monitor and assess systemic risk and to provide greater visibility for both FSOC and the Commissions into these arrangements
• Remove aggregate reporting for large hedge fund advisers to lessen the burden on advisers and to focus Form PF reporting on more valuable information for systemic risk assessment purposes

The final amendments will become effective one year after publication in the Federal Register, and the compliance date is the same as the effective date.

Reporting changes

Amendments to the form’s general instructions apply to all Form PF filers and were adopted to improve data quality and comparability to enhance investor protection efforts and systemic risk assessment.