SEC Releases 42-Page Form PF for Private Fund Information Filing
The SEC has released the new Form PF, which requires aggregated and specific information about private funds managed by fund managers now required to register as investment advisers pursuant to Dodd-Frank. The Form, which is 42 pages long plus another 21 pages of definitions, requires an extensive amount of very detailed fund information. All private fund managers must complete Section 1a and 1b (11 pages of data). Hedge fund managers with over $1.5 Billion in AUM must complete Section 2 (another 20 pages of data) and private equity managers with over $2 Billion in assets must complete Section 4 (4 pages of data). The instructions include information about how to handle fund-of-funds, master-feeder arrangements and sub-advised funds as well as calculation and timing.
OUR TAKE: It may have been less burdensome to require a statutory prospectus for all private funds.