Ten Key Lessons Learned From Test Filings of Form PF

When Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted in July 2010, some investment advisers worried about how changes to registration and reporting would impact them.  Chief among their anxieties was Form PF, a new filing requirement imposing substantial reporting requirements upon many investment advisers previously exempt from regulatory scrutiny.  More specifically, Form PF is a private, confidential filing required to be made by certain SEC-registered investment advisers on a quarterly or annual basis.  Designed to assist the Financial Stability Oversight Council in monitoring systemic risk, it requires the reporting of a broad range of data on private funds, including portfolio, performance and risk information.  In a guest article, Robert Diaz, managing director of SS&C GlobeOp, discusses ten broadly applicable lessons learned about Form PF preparation and filing.  These lessons are based on months of preparing and coordinating practice filings with SS&C GlobeOp clients.  This article also includes a chart offering a visual representation of the complexity and time pressure of many of the relevant data classifications in Form PF (e.g., RAUM, derivative exposure, etc.).

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