The SEC’s Form PF Rule 360: Round 1: “Current Reporting”


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The SEC believes it needs more information about private funds more quickly than ever in order to effectively monitor for potential financial stability impacts.  To this end, the SEC has recently finalised a series of new “current reporting” requirements for registered investment advisers that advise private funds and file the SEC’s Form PF, touching on: extraordinary investment losses, significant margin and default events, material changes in prime brokerage relationships, operational events, significant withdrawals/redemptions, inability to satisfy withdrawals/redemptions, adviser-led secondary transactions, claw backs, and investor initiated general partner removals, terminations of investment periods and fund terminations.  

The changes will affect large hedge fund advisers and all private equity advisers, with some advisers to private credit funds falling into each of those categories.  Given the short reporting periods, the complexity of the reporting thresholds and the short compliance period, timely compliance with these new requirements will pose a challenge for many advisers.

Please join us for a panel discussion designed to prepare registered investment advisers to face the quick fire and potentially painful new Form PF “current reporting” requirements.

Our panel of speakers include:

  • Jennifer Wood, AIMA’s Global Head of Asset Management Regulation and Sound Practice;
  • Christopher Simcox, Citco’s Executive Vice President Financial Statement and Regulatory Reporting;
  • Matthew Brady, Citco’s Senior Vice President Financial Statement and Regulatory Reporting;
  • Pádraig Murphy, Citco’s Senior Vice President Financial Statement and Regulatory Reporting.

Note that this program will cover the final rules on the portion of Form PF which the SEC controls alone.  The additional changes proposed to Form PF in August 2022, covering the areas of the form that are controlled jointly by the SEC and the CFTC, remain pending.