About a-team Marketing Services
The knowledge platform for the financial technology industry
The knowledge platform for the financial technology industry

A-Team Insight Blogs

Form PF’s Final Rules Reduce Tension for Fund Managers

Subscribe to our newsletter

The final rules of Form PF announced last week by the SEC have opened up a whole new era for hedge fund and private equity businesses, which will now be forced to disclose more information to the US government than previously required. As such, each entity should plan how they will address the Form’s requirements carefully, according to Kinetic Partners, a global professional services firm to asset management, investment banking and broking industries.

While the rules of Form PF require managers to now disclose more information to the Securities and Exchange Commission as outlined in the Dodd-Frank Reform Act, the final rules will also make it easier for them to report earnings than outlined in the original rules. One of the significant differences that the SEC has made in comparison to the Form’s original version is the Assets under Management (AUM) at which private fund advisors must report, which was raised from $1 billion to $1.5 billion.

Advisors will also now have a 60-day reporting deadline as opposed to the 15-day deadline that was initially proposed. In addition, Form PF will also take effect later than originally intended with advisors with over $5 billion AUM, the first to be affected, having to report in the middle of 2012.

Form PF applies only to private funds managed by registered investment advisers, registered commodity advisers and registered commodity pool operators. In particular, the three types of private funds that are covered include hedge funds, liquidity funds and private equity funds.

Advisers will need to understand numerous aspects of the Form PF including issues regarding related persons and the difference between reporting for individual funds and reporting for fund structures (master feeder, mini-master, parallel). It is essential that advisers plan ahead and perform a proper impact assessment, evaluate the necessary modifications to their existing systems, and communicate the impact of the filing of Form PF to all necessary parties.

“Form PF, for the US regulators, will become the new ADV and it will provide the examination staff and possibly the enforcement staff with a road map of how and what each fund is doing,” said Kevin Duffy of financial advisory firm Kinetic Partners. “It is imperative that each fund’s manager takes the time to seek professional advice to make sure that the initial filings are letter perfect and conform to the regulator’s expectations.”

The primary purpose of the 44-page Form PF is to collect information for the Financial Stability Oversight Council (FSOC) so that it may assess whether certain investment advisers possess inherent financial systematic risk. Therefore, it is possible that the FSOC may request additional information from certain filers based upon the information provided on Form PF.

Mr. Duffy added, “Although imperfect, the newly revised Form PF does provide each fund with ample time to comply with the legal directives now being administrated by the SEC and CFTC.”

Subscribe to our newsletter

Related content

WEBINAR

Upcoming Webinar: Best approaches for trade and transaction reporting

11 September 2025 10:00am ET | 3:00pm London | 4:00pm CET Duration: 50 Minutes Compliance practitioners and technology leaders in capital markets face mounting pressure to ensure that reporting processes are efficient, accurate, and aligned with global standards. Market developments and jurisdictional nuances in regulatory frameworks like MiFID II, EMIR, SFTR and MAS create a...

BLOG

FCA Rings the Bell for PISCES – A New Market for Private Company Shares

The Financial Conduct Authority (FCA) has launched the Private Intermittent Securities and Capital Exchange System (PISCES). Announced as an innovative sandbox initiative, PISCES represents a significant evolution in the structure and accessibility of private company shares, through periodic trading events under a tailored regulatory environment. Designed as a five-year pilot, the initiative seeks to test...

EVENT

Data Management Summit London

Now in its 16th year, the Data Management Summit (DMS) in London brings together the European capital markets enterprise data management community, to explore how data strategy is evolving to drive business outcomes and speed to market in changing times.

GUIDE

AI in Capital Markets: Practical Insight for a Transforming Industry – Free Handbook

AI is no longer on the horizon – it’s embedded in the infrastructure of modern capital markets. But separating real impact from inflated promises requires a grounded, practical understanding. The AI in Capital Markets Handbook 2025 provides exactly that. Designed for data-driven professionals across the trade life-cycle, compliance, infrastructure, and strategy, this handbook goes beyond...