Final Form PF Amendments: Compliance Challenges and Implications (Part Two of Two)

Now, private fund advisers are required to file Form PF on a quarterly or annual basis, depending on the size and type of their hedge or private equity funds. That all changed when the SEC adopted final amendments to Form PF in May 2023 that will require large hedge fund advisers to file so-called “current” reports no later than 72 hours after designated events occur. The changes reflect a significant paradigm shift for hedge fund managers. This second article in a two-part series examines the compliance challenges posed by the current reports and the short‑ and long‑term implications of the new reporting requirements. The first article discussed the final changes to Form PF relevant to large hedge fund advisers, the SEC’s rationale for the amendments and the Commissioners’ views on the changes. See our two-part series on the originally proposed changes to Form PF: “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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