SEC Updated Form PF FAQs

The SEC has updated its frequently asked questions on Form PF.  The updates include:

  • General filing information: Questions A.7 through A.9 on rounding, amendments to Form ADV on new private funds, and liquidation of funds.
  • Question 14.2 on assets and liabilities in the cost-based column that would be presented in a fund’s financial statements using a measurement attribute other than fair value.
  • Question 24.3 on use of gross notional values for trading data.
  • Question 35.2 indicating cash and cash equivalents are not a “position” for purposes of reporting open positions in Questions 35 and 57.
  • Question 46 addressing whether guidance provided by the staff regarding borrowings for Question 12 and 43 also apply to how borrowings should be interpreted for Questions 46 and 47.
  • Question 47, which refers to Question 46.

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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