Published on Apr 17th, 2023 |


Form PF Filings are Due at the End of the Month
(April 30th, 2023)

Vigilant Insights

Brief Introduction

SEC Registered Investment Advisers (“RIAs”) that manage Private Funds must file their Form PF by April 30th, 2023, if they meet certain requirements.

With less than two weeks to file, Vigilant has a few reminders for RIAs that are affected by this requirement.

Form PF Filing Reminders

  • Form PF is required if you had at least $150 million in private funds AUM at the end of the most recently completed fiscal year.
  • Section 1 of Form PF must be completed at least annually within 120 days of the firm’s fiscal year end.
  • Large Private Advisers may be required to provide data in Sections 2, 3, and 4.
  • Large Hedge Fund Advisers and large Liquidity Fund Advisers must file every quarter, 60 days prior to the end of each quarter.
  • It is vital that the methods you choose for data, such as valuation, are well documented and defendable.

Mistakes to Avoid

  • The Private Fund Identification Numbers are generated or displayed on the Form ADV; make sure you review these numbers for each Fund.
  • Make one final comparison of valuation and data in Form PF against the numbers reported on Form ADV.
  • Your IARD account must have the $150 Filing Fee, or else the Form will not be accepted.
  • If additional Private Funds are necessary, you may need to file an other-than-annual ADV amendment to generate identification numbers for additional funds. The same identifier must be used for all future filings on forms like Form PF.

Vigilant’s Conclusion

This Form may take a significant amount of time and effort, considering the large amount of information necessary to complete Form PF.

It is important for Advisers to work diligently with their associates to get all the required data.

We recommend relying on specialized professionals with years of experience providing Firms with the resources required to remain compliant in their SEC filings.

Please reach out to us for any assistance you may need.

Contact Vigilant Today