Final Form PF Amendments: Enhanced Reporting for Large Hedge Fund Advisers (Part One of Two)

In January 2022, the SEC proposed amendments (Proposal) to Form PF to enhance the information provided by private fund advisers by requiring more frequent reporting for large hedge fund advisers and private equity (PE) advisers upon the occurrence of certain events, as well as amending reporting requirements for large PE advisers and large liquidity fund advisers. On May 3, 2023, the SEC adopted, with some significant modifications, the amendments in the Proposal. This article, the first in a two-part series, discusses the final changes to Form PF relevant to large hedge fund advisers – noting the key differences from the Proposal – the SEC’s rationale for the amendments and the Commissioners’ views on the changes. The second article will discuss the compliance challenges posed by the current reports triggered by designated events and the short‑ and long‑term implications of the new reporting requirements. See our two-part series on the Proposal: “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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