Proposed Form PF Amendments Would Require Prompt Reporting of Certain Stress Events and Enhanced Reporting by Large Liquidity Fund Advisers (Part One of Two)

The SEC recently voted, over a spirited dissent from Commissioner Hester M. Peirce, to propose amendments to Form PF (Proposal) in several broad areas. First, the Proposal would require large hedge fund advisers and all private equity advisers to file a report within one business day after the occurrence of certain stress events that could have an adverse impact on investors or the broader financial markets. In addition, the Proposal would revise and enhance reporting by large liquidity fund advisers. The comment period for the Proposal expires March 21, 2022. This first article in a two-part series details the SEC’s reasoning behind the Proposal, the proposed changes that will impact hedge fund managers and the topics under consideration during the comment period. The second article will break down the individual SEC Commissioners’ remarks on the Proposal; concerns in the private funds industry about the Proposal’s scope and practical impact; and the likelihood of it being enacted. See “The SEC’s 2021 Reg Flex Agendas: Key Items for Private Funds and the Rulemaking Process (Part Two of Two)” (Aug. 26, 2021); and “Former OCIE Official Discusses SEC’s Latest Reg Flex Agendas” (Sep. 24, 2020).

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