Form PF Current Reports: Monitoring for Trigger Events (Part One of Two)

The days of private fund advisers filing Form PF on a quarterly or annual basis only are over. As of December 11, 2023, when certain amendments to Form PF (Amendments) took effect, large hedge fund advisers are now required to file so-called “current” reports on Form PF no later than 72 hours after designated events occur. As a result, hedge fund managers must now monitor for the occurrence of such events, determine whether a reporting obligation has been triggered and, if so, ensure that a Form PF current report is filed by this very short deadline. Each step of the process poses its own challenges. This first article in a two-part series discusses the challenges hedge fund managers face in monitoring for current events and the approaches managers have taken for this task. The second article will examine how managers are determining whether a Form PF reporting obligation has arisen and ensuring that a complete and accurate current report is filed in a timely manner, if required. See our two-part series on the Amendments: “Enhanced Reporting for Large Hedge Fund Advisers” (Jun. 22, 2023); and “Compliance Challenges and Implications” (Jul. 6, 2023).

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