Compliance Corner Q2‑2022: Regulatory Filings and Other Considerations That Hedge Fund Managers Should Note in the Coming Quarter

Not since Dodd-Frank have private fund managers seen as much regulatory attention as they have over the past quarter. In the past few months, the SEC has proposed amendments to Form PF that affect large hedge fund advisers and advisers to private equity funds; released a risk alert highlighting deficiencies uncovered in the examination of private fund managers; and proposed new rules and rule amendments to address “concerns that arise out of the opacity that is prevalent in the private fund structure.” That volume of rule proposals can present significant challenges for CCOs trying to balance their time between preparing for those potential regulations and also managing compliance programs to align with both the current regulatory attention being directed toward private fund managers and the upcoming compliance date for the new marketing rule. This twentieth installment of the Hedge Fund Law Report’s quarterly compliance update, authored by ACA Group’s Dan Campbell, highlights upcoming filing deadlines and reporting requirements that fund managers should be aware of during the second quarter. The article also analyzes the SEC’s 2022 Examination Priorities, proposed cybersecurity risk management requirements for registered advisers and proposed rule amendments to beneficial ownership reporting. See our two-part series on the proposed Form PF amendments: “Prompt Reporting of Certain Stress Events and Enhanced Reporting by Large Liquidity Fund Advisers” (Mar. 3, 2022); and “Practical Impact on Fund Managers and Reasons for Industry Backlash” (Mar. 10, 2022); as well as our two-part series on the proposed private fund rules: “General Observations” (Apr. 7, 2022); and “Rule‑Specific Concerns and Next Steps” (Apr. 14, 2022). See also “SEC Risk Alert Reflects Growing Concerns About and Focus on Private Funds” (Feb. 24, 2022).

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