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Register NowRegulatory Reporting Recap: Form PF
An overview of the SEC’s proposed amendments
In January 2022, the U.S. Securities and Exchange Commission (SEC) announced the proposal of several amendments to Form PF that will impact private equity and hedge fund advisers. Form Private Fund (Form PF) is a SEC regulatory filing requirement that mandates private fund advisers to report regulatory assets under management (quarterly/annually) to the Financial Stability Oversight Council (FSOC). The form, which was first adopted in 2011 and became effective in 2012, was created to monitor and assess systemic risks to the U.S. financial system. Since 2012, the entire ecosystem has gone through a myriad of changes with many private equity and hedge funds added over the years.
Proposed Amendments
New Current Reporting Requirements for Large Hedge Fund Advisers and All Private Equity Advisers:
The latest changes to Form PF would require large hedge fund advisers and private equity advisers to file a current report within one day after certain events that may signal “significant stress,” “potential systemic risk implications” or “potential areas of inquiry to prevent investor harm.”
The following are the events that will trigger current reporting:
Large Private Equity Adviser Reporting:
Currently, a large private equity adviser manages $2 billion AUM. In the latest changes to Form PF, the SEC has revised the limit to $1.5 billion AUM. The SEC expects this change to increase the percentage of the U.S. private equity industry covered by Section 4 of Form PF from 67 percent to 75 percent based on committed capital, thus improving the SEC’s ability to monitor systemic risk. Furthermore, the proposal would amend Section 4 of Form PF.
The additional and amended questions would collect information on:
New Reporting Requirements for Large Liquidity Fund Advisers:
The proposed updates to Form PF are designed to provide the SEC with a holistic picture of the short-term financing markets in which liquidity funds invest. If adopted, they would revise how large liquidity fund advisers disclose operational information and assets, as well as portfolio, financing and investor information. The proposed changes would bring large liquidity advisers in parity with money market funds in terms of reporting requirements.
Section 3 of Form PF would be amended to require large liquidity fund advisers to report:
It is only a matter of time until these proposed updates to Form PF come into effect, which all alternative investment managers must comply with. Are your systems flexible enough to adapt?
Learn how IVP’s Regulatory Reporting solution can help by visiting Regulatory Reporting or contacting sales@ivp.in.
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