SEC Proposes Amendments to Form PF (UPDATED)

The Securities and Exchange Commission on January 26, 2022 voted three to one to propose amendments to Form PF, a confidential reporting form for certain SEC-registered investment advisers to private funds. The amendments would: (1) require current reporting of certain key events for large hedge fund advisers and advisers to private equity funds, to aid in identifying fund distress or market instability; (2) reduce from $2 billion to $1.5 billion the reporting threshold for large private equity advisers, and require additional reporting regarding fund strategies to enhance information accessible to the SEC and FSOC; and (3) revise reporting requirements for large liquidity fund advisers to be more in line with proposed reporting requirements for money market funds in order to assess the short-term financing markets. The amendments would impact large hedge fund advisers, private equity advisers and large liquidity fund advisers. The proposing release (Release) indicates that the amendments “are designed to enhance FSOC’s monitoring and assessment of systemic risk” and to “collect additional data for the [SEC]’s use in its regulatory programs.”

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