The SEC voted to require hedge fund and private equity fund managers to file new Form PF, which will require detailed information about the funds they manage.  All SEC registered investment advisers that have more that $150 Million in assets in private funds will be required to file Form PF.  Large private fund advisers — hedge managers with more than $1.5 Billion in funds and private equity managers with more than $2 Billion in funds — must file quarterly.  The form will require aggregated information about investor types, fund strategy, exposures, concentrations, leverage, assets, and turnover.  Smaller fund managers must file annually and there will be less information required.  Firms with more than $5 Billion in fund assets must begin filing in the 3^rd quarter of 2012 and others must begin the first quarter of 2013.  The SEC will provide the data to the Financial Stability Oversight Council for the purpose of monitoring systemic risk.

OUR TAKE: We expect that Form PF will create a significant administrative burden on private fund managers.  We also expect third party vendors (e.g. administrators, financial printers) will step up to assist with the creation and filing of the forms.