Form PF

Form PF

Author: The Carta Team
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Read time:  4 minutes
Published date:  6 June 2024
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Updated date:  6 June 2024
Form PF is a regulatory filing required of all SEC-registered private fund advisers with at least $150 million in assets under management.

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:

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. 

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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

Section 1

Required for all fund advisers who file Form PF

Section 2

Required for large hedge fund advisers who have $1.5 billion or more in hedge fund AUM

Section 3

Required for advisers of large liquidity funds with more than $1 billion in combined money market and liquidity fund AUM

Section 4

Required for advisers of large private equity funds with more than $2 billion in AUM

Section 5

Supplementary form that large hedge fund advisers must use to report specific events within 72 hours. These events include extraordinary investment losses, certain kinds of withdrawals and redemptions, and significant margin and default events, among others outlined in the instructions to Section 5. 

Section 6

Supplementary form that private equity advisers use to make quarterly reports on any fund-related events that may affect the stability of the private markets. These events include the removal of a general partner and adviser-led secondary transactions, among others outlined in the instructions to Section 6.

Section 7

Application for a temporary hardship exemption

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. 

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The Carta Team
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