SEC Staff Offers More Form PF Guidance
The SEC has issued more responses to Form PF frequently asked questions. Most significantly, the staff indicates that firms need not revise previously filed forms or change programming assumptions for an impending filing even though inconsistent with later staff guidance so long as the firm lists its (reasonable) assumptions in response to Question 4 and makes the changes in the future. The FAQs also respond to several issues about derivatives calculations including short sales and borrowings. The staff also acknowledges that the Form does not yet account for relying advisers filing under the same ADV but that firms should list all relying advisers in its response to Question 4. Form PF is the form required of private fund advisers with respect to their private funds.