Joint SEC-CFTC proposal would overhaul Form PF reporting

Hogan Lovells
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The U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) proposed joint amendments to Form PF, a confidential reporting form required of certain SEC-registered investment advisers (RIAs) to private funds, on Wednesday, 10 August 2022. The amendments would enhance reporting requirements for all private fund advisers, hedge fund advisers in particular, and are designed to refine the federal government’s ability to monitor systemic risk from private funds, including the use of leverage.

The proposed amendments, in short:

• enhance reporting of basic information about all advisers and the private funds they advise;

• clarify how all advisers should report complex structures, such as master-feeder and parallel fund structures;

• enhance reporting by large hedge fund advisers on “qualifying hedge funds” (i.e. those hedge funds with a net asset value of at least US$500 million);

• enhance additional reporting about all hedge funds, generally; and

• remove aggregate reporting for large hedge fund advisers.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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