Filing fees are charged by FINRA to use the IARD system. The filing fees for SEC-registered investment advisers filing Form PF using the IARD system are $150 for each annual report and $150 for each quarterly report.
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How do you file Form PF?
November 02, 2018
Form PF must be filed electronically through the Form PF filing system on the Investment Adviser Registration Depository (IARD) website.
What are the compliance dates for Form PF?
November 02, 2018
For currently registered investment advisers and firms that register as investment advisers in 2012, Form PF has a two-stage period for filing.
When does Form PF have to be updated?
November 02, 2018
“Small” and “large” private equity fund advisers must file Form PF annually within 120 days after the end of their fiscal year. They must respond to questions focusing primarily on the extent of leverage incurred by their funds’ portfolio companies, the use of bridge financing, and their funds’ investments in financial institutions.
Advisers that have at least $150 million in private fund assets under management but that do not exceed a “large adviser” threshold must file Form PF only once a year. These “small” private fund advisers are required to fill out basic information on the private funds they advise. This includes limited information regarding size, leverage, investor types and concentration, liquidity, and fund performance. The “smaller advisers” managing hedge funds must also report basic hedge fund information. This includes fund strategy, counterparty credit risk, and use of trading and clearing mechanisms.
Who is required to file Form PF?
November 02, 2018
Investment advisers must file a Form PF if registered or required to register with the SEC as an investment adviser; or if registered or required to register with the U.S. Commodity Future Trading Commission (CFTC) as a CPO or CTA and also registered or required to register with the SEC as an investment adviser; and manage one or more private funds; and the investment adviser and its related persons, collectively, had at least $150 million in private fund assets under management as of the last day of its most recently completed fiscal year. The due date for Form PF varies depending on the classification and size of the investment adviser. Many private fund advisers meeting these criteria will be considered a “small” adviser and be required to complete only Section 1 of Form PF and will need to file only on an annual basis. Large private fund advisers, however, will be required to provide additional data, and large hedge fund advisers and large liquidity fund advisers will need to file every quarter.
What is the purpose of Form PF?
November 02, 2018
Form PF was adopted by the SEC following the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). “The Dodd-Frank Act amended section 204(b) of the Investment Advisers Act of 1940 (“Advisers Act of 1940″) to require the SEC to establish reporting and recordkeeping requirements for advisers to private funds.” The SEC adopted Form PF “to obtain data that will facilitate monitoring of systemic risk in U.S. financial markets.” Form PF covers all private funds including private equity funds, hedge funds and liquidity funds.
