Meeting the Requirements of Filing Form PF
February 7, 2013
1:00 PM – 3:00 PM ET
In October 2011 the SEC and the CFTC jointly adopted new rules to implement Sections 404 and 406 of the Dodd-Frank Act. The rules require investment advisers registered or required to be registered with the SEC that advise one or more private funds to file “Form PF” with the SEC, on a confidential basis. The purpose of Form PF is to gather information to assist the Financial Stability Oversight Council (also created by the Dodd-Frank Act) in monitoring and responding to systemic risks to financial market stability. Both the SEC and the CFTC are allowed to use Form PF information in their regulatory programs, including examinations, investigations and enforcement actions.
For the majority of private fund advisers with a December 31 fiscal year end, the initial Form PF filing deadline is April 30, 2013—120 days after fiscal year end. The level and frequency of an adviser's Form PF reporting varies depending on the total amount and type of private fund assets advised by the adviser. Generally, more detailed reporting will be required from large hedge fund and large private equity advisers.
This course will focus on Form PF reporting classifications and reportable information pertaining to each reporting classification. The course will also include an overview of suggested action steps to facilitate your firm’s Form PF filing process and internal controls.
After attending this course, attendees should be able to:
- Identify sections of Form PF that must be completed by your firm and relevant reportable information
- Understand how to calculate regulatory assets under management for purposes of determining your firm’s reporting obligations
- Delineate Form PF aggregation requirements to ascertain your firm’s reporting classification, including asset aggregation with separate accounts and/or clients advised by affiliates
- Determine how private fund assets invested in the equity of other private funds (fund-of-funds) impact your firm’s filing classification
- Understand the handling of reporting requirements for affiliates and sub-advisers
- Apply reporting guidance from SEC FAQs
- Understand confidentiality of information submitted on Form PF
For Whom: Private Fund staff at All Levels, Chief Compliance Officers, Legal Counsel, Compliance Staff at All Levels and Management
Suggested Skill Level: Intermediate
Instructional Method: Group Internet-Based
Prerequisites for Participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940 to become familiar with the structure and terms.
Advance Preparation: None
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