Second Form PF Proposal: Overview and Goals (Part One of Two)

Despite proposing amendments to Form PF at the start of 2022 that would require large hedge fund advisers and all private equity advisers to file a report within one business day of certain stress events, the SEC was not done tinkering with Form PF. The Spring 2022 “Reg Flex” agenda listed further amendments to Form PF at the proposed rule stage of the short-term agenda – and the SEC wasted no time fulfilling that agenda item. The SEC, in conjunction with the CFTC, recently proposed a second set of amendments (Proposal) to the Form PF reporting requirements for all filers and large hedge fund advisers, with a deadline for comments to the Proposal looming less than a month away. This article, the first in a two-part series, provides an overview of the Proposal and its five goals. The second article will discuss the rationale for the Proposal; the views of Commissioners from the SEC and CFTC on the Proposal; and reasons thoughtful comments to the Proposal are so important. See our two-part series on the first set of 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).

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