- Form PF
- What is Form PF?
- Who must file Form PF?
- What information do RIAs report on Form PF?
- Sections of Form PF
- When is Form PF due?
- Form PF fees
- Form PF filing instructions
- History of Form PF
- Changes to Form PF
- How agencies use data from Form PF
- Confidentiality of Form PF data
- Get the latest policy updates
What is Form PF?
Form PF is a regulatory filing that certain private fund advisers must file with the U.S. Securities and Exchange Commission (SEC). The Treasury’s Financial Stability Oversight Council (FSOC) uses detailed information from Form PF to gain visibility into the behaviors and risk profiles of private funds.
Who must file Form PF?
Investment advisers must file Form PF if they meet all three of the following criteria:
-
They are an SEC-registered investment adviser (RIA)
-
They advise at least one private fund, including private equity funds, venture capital funds, and hedge funds
-
They had at least $150 million in assets under management (AUM) as of the close of their last fiscal year
Exempt reporting advisers (ERAs), a type of investment adviser that is not required to register with the SEC or a state securities regulator, do not have to file Form PF.
What information do RIAs report on Form PF?
Form PF has several parts and various reporting obligations. Most private fund advisers are only required to complete Section 1. Large private equity fund advisers and large hedge fund advisers have additional (and more frequent) Form PF reporting requirements.
Instructions to Form PF outline the types of advisers that are required to complete each section:
Sections of Form PF
For more details about each section of Form PF, see the instructions on the form.
When is Form PF due?
Fund advisers who are required to file Form PF must do so within 120 days of the end of their fiscal year. For example, if your fiscal year ended on December 31, 2023, the deadline to file Form PF was April 29, 2024. For the fiscal year ending on December 31, 2024, the deadline to file will be April 30, 2025.
The SEC also requires periodic updates to Form PF, depending on the adviser’s assets under management:
| Adviser category | Updates required |
| Large hedge fund advisers | Quarterly, <60 days from close of fiscal quarter |
| Liquidity fund advisers | Quarterly, <15 days from close of fiscal quarter |
| All other advisers | Annually, <120 days from close of fiscal year |
If you advise multiple funds, the deadlines for updated filings on each of your funds correspond to the fund type, as outlined above.
Form PF fees
The processing fee for the initial filing and every subsequent update is $150. Funds required to make quarterly filings therefore pay $600 per year in Form PF filing fees.
Form PF filing instructions
The SEC does not accept paper filings. RIAs must file Form PF through the Investment Adviser Registration Depository (IARD). Required updates must also be filed through IARD.
History of Form PF
In response to the Global Financial Crisis of 2008, Congress passed the Dodd-Frank Act of 2010, a law aimed at reforming financial-sector regulation and ensuring greater stability and oversight in the financial sector. One of the law’s provisions required the SEC and the Commodity Futures Trading Commission (CFTC) to adopt a joint form for collecting additional information related to private AUM. In October 2011, the two agencies formally adopted Form PF along with Rule 204(b)-1, which lays out Form PF filing requirements. Private funds began complying with the rule in 2012.
Changes to Form PF
The SEC and CFTC periodically amend Form PF to address changing market conditions. Most recently, regulators have amended Form PF to enhance their understanding of large hedge fund advisers in particular.
How agencies use data from Form PF
The information collected on Form PF is primarily intended for use by FSOC to monitor the stability of the financial system. However, SEC can also use data from Form PF to aid routine examinations or investigations into private fund advisers.
Confidentiality of Form PF data
Unlike other regulatory filings, Form PF filings are confidential—meaning they are not available to the public. Under Dodd-Frank, the SEC is even authorized to withhold Form PF information from Congress. The law also prevents the SEC from supplying Form PF data to other federal departments and regulatory agencies, and forbids the agency from furnishing Form PF data in response to a court order or Freedom of Information Act (FOIA) request.
Get the latest policy updates
To stay up-to-date on the latest news in private-market regulation, sign up below to receive the Carta Policy Team's weekly brief:
