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.

The SEC adopted a threshold of $2 billion in private equity fund assets under management to be considered a “large” private equity fund adviser. Form PF defines “private equity fund” as any private fund that is not a hedge fund, liquidity fund, real estate fund, securitized asset fund or venture capital fund and does not provide investors with redemption rights in the ordinary course.

The SEC adopted a threshold of $1.5 billion in hedge fund assets under management to be considered a “large” hedge fund adviser. Form PF defines hedge fund generally to include any private fund having any one of three common characteristics of a hedge fund: (a) A performance fee that takes into account market value (instead of only realized gains); (b) high leverage; or (c) short selling.

The SEC adopted a threshold of $1 billion to be considered a “large” liquidity fund adviser. Form PF defines liquidity fund as any private fund that seeks to generate income by investing in a portfolio of short term obligations in order to maintain a stable net asset value per unit or minimize principal volatility for investors.