Proposed Amendments to Form PF
What happened?
Since its adoption in 2011, Form PF has been used by private fund advisers to describe required information regarding their fund’s operations. On August 10, 2022, the SEC proposed amendments to Form PF that “are designed to provide greater insight into private funds’ operations and strategies” (see the proposal announcement and accompanying fact sheet). The proposed amendments would result in the following reporting requirements for:
All private funds:
- Additional reporting requirements for general information on advisers to private funds and private funds themselves. Topics include assets under management, identifying information, withdrawal and redemption rights, gross asset value and net asset value, inflows and outflows, base currency, borrowings and types of creditors, fair value hierarchy, beneficial ownership, and fund performance.
All hedge funds:
- Adds reporting requirements for “fund investment strategies, counterparty exposures, and trading and clearing mechanisms.”
Complex structures:
- Requires advisers to report complex fund structures, i.e. master-feeder arrangements and parallel fund structures, separately. Current requirements allow for such structures to be reported either separately or in aggregate, and the proposal does away with the aggregated option.
Large hedge fund advisers
- Removing requirement for advisers to report aggregated information on hedge funds they manage (Section 2a). Like the change for complex fund structures, aggregated information can obscure data about risk and directional exposure of individual funds and make comparison difficult, thus the Commission’s proposed amendment to move away from aggregated reporting.
- For any hedge funds that have a net asset value at least $500 million, revised reporting requirements for items such as investment exposures, borrowing and counterparty exposure, market factor effects, currency exposure reporting, turnover, country and industry exposure, central clearing counterparty reporting, risk metrics, investment performance by strategy, portfolio correlation, portfolio liquidity, and financing liquidity.
What does this mean for me?
Fairview will continue to update you with in-depth information about proposed SEC regulations and how your firm may be affected. Fairview Investment Services provides comprehensive and ongoing compliance services, including comprehensive marketing review, solicitation-related consulting, and complete examination support. Contact Fairview Investment Services for additional information about maintaining your compliance program in an ever-changing regulatory environment.
