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Who is required to file Form PF?


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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.

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