January 20, 2020

January 17, 2020

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SEC Releases 16 New FAQs on Form PF

On January 18, 2017, the SEC released 16 new FAQs relating to Form PF. Of these 16, 3 relate to general filing information and the remaining 13 are specific to particular sections of Form PF. As a reminder, Rule 204(b)-1 under the Investment Advisers Act of 1940 requires that all registered investment advisers managing private fund assets of at least $150 million must file Form PF via the Form PF filing system on the Investment Adviser Registration Depository. For registered advisers to private funds not subject to quarterly reporting on Form PF, the annual Form PF amendment is due within 120 days after the date of the adviser's fiscal year-end. Accordingly, in 2017, a registered adviser to one or more private funds adhering to a calendar fiscal year would be required to file Form PF on or before May 1, 2017. Large advisers subject to quarterly reporting requirements are required to file such amendments within either 60 days after each quarter-end (for large hedge fund advisers) or 15 days after each quarter-end (for large liquidity fund advisers).

This chart summarizes the new FAQs by reference to the question they pertain to on Form PF.


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About this Author

Robert G Leonard, Proskauer Rose Law Firm, Private Investment Attorney

Robert G. Leonard is a Partner in the Hedge Funds Group. For more than 25 years Rob has been structuring, organizing and representing hedge funds, funds of funds and other private investment funds (both domestic and offshore) and investment advisers.

Sean J Hill, Prosakuer Law Firm, Private Investment Attorney

Sean J. Hill is a Partner and co-head of the Private Investment Funds Group. His practice covers a full range of activities and operations of alternative investment managers, with a particular emphasis on representing U.S. and non-U.S. sponsors in fund formation and portfolio activities, as well as regulatory, compliance and operational issues. Sean works with fund sponsors to structure firm ownership and operations. He also advises clients with respect to third-party investments in, and acquisitions of, alternative investment managers.

Anthony M. Drenzek, Special regulatory Counsel, Proskauer Rose, Attorney, Finance Policy Lawyer
Special Regulatory Counsel

Tony is special regulatory counsel in the Corporate Department and a member of the Private Funds Group and the Private Equity & Hedge Fund Litigation team. His practice focuses on advising U.S. and offshore private fund managers on all aspects of federal, state and SRO organizational and operational compliance, with a specific emphasis on the Investment Advisers Act of 1940.

Tony assists U.S. and offshore private fund clients in registering with the SEC as investment advisers, or reporting as exempt reporting advisers, and complying with...