SEC Staff Issues More Form PF FAQ Responses
The staff of the SEC’s Division of Investment Management has posted new Form PF FAQ responses. The staff offered the following: (a) if a firm needs to file an other-than-annual Form ADV amendment to add a private fund (Item 7.B.1), it need not update all the other Form ADV questions; (b) Form PF must include a fund liquidated during a reporting period but use “0” or “N/A” with date specific information; and (c) cash and cash equivalents are not considered “positions” for questions 35 and 57. The staff also offered some technical guidance on derivatives, valuation, and borrowings.
OUR TAKE: We are now up to 78 frequently asked questions. At some point, the staff should re-vamp the form and its instructions to account for the learning over the last couple of years.