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When does Form PF have to be updated?


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“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.

Large hedge fund advisers must file an updated Form PF within 60 calendar days after the end of their first, second and third fiscal quarters. They must file a quarterly update that answers all Items in Form PF relating to the hedge funds that are advised. Within 60 calendar days after the end of their fourth fiscal quarter, large hedge fund advisers must file a quarterly Form PF update that updates the answers to all items. Large hedge fund advisers may, however, submit an initial filing for the fourth quarter that updates information relating only to the hedge funds they advise so long as they amend Form PF within 120 calendar days after the end of the quarter to update information relating to any other private funds they advise. When large hedge fund advisers file such an amendment, they are not required to update information previously filed for such quarter.

Large liquidity advisers must file an updated Form PF within 15 calendar days after the end of their first, second and third fiscal quarters. They must file a quarterly update that updates the answers to all Items in the Form PF relating to the liquidity funds they advise. Within 15 calendar days after the end of their fourth fiscal quarter, large liquidity advisers must file a quarterly update that updates answers to all Items in their Form PF. Large liquidity advisers may, however, submit an initial filing for the fourth quarter that updates information relating only to the liquidity funds they advise so long as they amend Form PF within 120 calendar days after the end of the quarter to update information relating to any other private funds they advise (subject to the next paragraph). When a large liquidity adviser files such an amendment, it is not required to update information previously filed for such quarter.

Advisers who are both a large hedge fund adviser and a large liquidity fund adviser must file within 15 calendar days after the end of each quarter for liquidity funds and within 60 days for large hedge funds.

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