SEC Staff Gives More Form PF Guidance
The staff of the Division of Investment Management has released additional responses to frequently asked questions about Form PF. Most of these new FAQs from March and April offer guidance on the reporting of derivatives, fairly-valued securities, master-feeder arrangements, and redemption limitations. For example, one FAQ advises to value derivatives using the applicable accounting standards applied for balance sheet reporting. Another new FAQ tells reporting persons to treat a master-feeder fund complex as one entity for purposes of counting investors. The staff also tells reporting persons that the Question 14 hierarchy reporting (Level 1, 2, 3) is only relevant for fairly valued securities.
OUR TAKE: It’s a high bar but Form PF may be the most complicated of SEC forms. The staff has already released 21 pages of responses to frequently asked questions, and the form has not yet reached its first birthday