Joint SEC-CFTC proposal would overhaul Form PF reporting

The proposed amendments, in short: 

• enhance reporting of basic information about all advisers and the private funds they advise;
• clarify how all advisers should report complex structures, such as master-feeder and parallel fund structures; 
• enhance reporting by large hedge fund advisers on “qualifying hedge funds” (i.e. those hedge funds with a net asset value of at least US$500 million); 
• enhance additional reporting about all hedge funds, generally; and 
• remove aggregate reporting for large hedge fund advisers. 

The proposed amendments are available in full here, which includes a full draft amended version of Form PF. The public comment period will remain open through the later of (i) 60 days following publication of the proposing release on the SEC’s website (i.e. 11 October 2022) or (ii) 30 days following publication of the proposing release in the Federal Register, whichever period is longer. 

Authored by Adam Brown, Parikshit Dasgupta, Henry Kahn, Bryan Ricapito, David Winter, and Kevin Lees.