Published on Jan 30th, 2025 |

Form PF Amendments Compliance Date Extension

SEC RELEASES

Introduction

On January 29th, 2025, the SEC and CFTC extended the compliance date for the amendments to Form PF that were adopted on February 8th, 2024. The compliance date for these amendments, which was originally March 12th, 2025, has been extended to June 12th, 2025.

This set of amendments to Form PF has amended reporting requirements that apply to all Form PF filers, amendments that apply only to Advisers to Hedge Funds, and amendments that apply solely to large Hedge Fund Advisers that advise qualifying Hedge Funds.

Key Takeaways and Changes

Key Takeaways and Changes

  • This extension will:
    • Mitigate certain administrative and technological burdens and costs associated with the prior compliance date.
    • Allow more time for filers to program and test for compliance with these amendments.
  • The amendments remove the ability from the current Form PF to aggregate Master and Feeder Fund structures for all Private Fund Advisers. Filers will now have to separately report each component Fund of a Master-Feeder arrangement and parallel Fund structure.
  • Advisers must include the value of Private Fund investments in other Private Funds (including internal and external Private Funds) when determining whether the Adviser meets the filing threshold to file Form PF..
  • The amendments require advisers to identify trading vehicles in section 1b of Form PF and report on an aggregated basis for the reporting Fund and all trading vehicles on a consolidated basis.
  • For quarterly filers (large Hedge Fund and Liquidity Fund Adviser), the amendments will require them to file on a calendar quarter basis.
  • Amendments were made to sections 1a and 1b of Form PF to collect additional identifying information regarding the adviser, its related persons, and Private Fund assets under management (AUM). There is also additional identifying information about the Private Funds’ assets, financing, investor concentration, and performance.
  • For Hedge Fund Advisers, there were modifications made to section 1c of Form PF that include additional reporting concerning:
    • Borrowing and financing arrangements with counterparties.
    • Hedge Fund investment strategies.
    • Trading and clearing mechanisms.
  • For large Hedge Fund Advisers, sections 2a and 2b of Form PF were amended and it re-designated existing sections and consolidated them into section 2. This requires additional Fund level reporting about the reporting Fund’s:
    • Open and large position reporting.
    • Market factor effects.
    • Investment exposure.
    • Borrowing and counterparty exposure.
    • Certain reporting on the reporting Fund’s turnover and exposure.
  • For Liquidity Fund Advisers, amendments were made to section 3 of Form PF, which are:
    • Revision of the data being reported for identifying and operational information of the reporting Fund.
    • Redemptions, subscriptions, and cash holdings require additional reporting.
    • Certain reporting requirements regarding the Fund’s investors, along with expanded details on portfolio holdings, maturity, liquidity, and the sales of securities.

Vigilant's Conclusion

Vigilant’s Conclusion

These amendments have a significant impact for Private Funds. The volume and complexity of the data required to comply with these amendments to Form PF will substantially increase compared to the current reporting standards. It is important that Advisers are fully aware of the resources that may be required to remain in Compliance.

As Private Funds see the need to invest in their Compliance Programs, Vigilant is prepared to provide the support that will be needed as it relates to the various regulatory filing requirements, regulatory commitments and on-going compliance monitoring and execution. Schedule a call with Vigilant to learn more about how we can help.

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