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 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; you and your related persons, collectively, had at least $150 million in private fund assets under management as of the last day of your 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 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.

The SEC adopted a threshold of $2 billion in private equity fund assets under management for large private equity fund advisers. Large private equity fund advisers and smaller private equity fund advisers have 120 days from the end of their fiscal years to file Form PF but large private equity fund advisers must provide more information than small private fund advisers. 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 for large hedge fund adviser reporting. Large hedge fund advisers have 60 days from the end of each fiscal quarter to file Form PF. 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 for liquidity funds. Large liquidity fund advisers have 15 days from the end of each fiscal quarter to file Form PF. 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.