SEC Proposes Changes to Form PF (UPDATE) | Dechert LLP


On January 26, 2022, the Securities and Exchange Commission voted three to one to propose changes to Form PF, a confidential reporting form for certain SEC-registered investment advisers to private funds. The changes: (1) would require current reporting of certain key events for large hedge fund advisers and private equity fund advisers, to help identify fund difficulties or market instability; (2) reduce the reporting threshold for large private equity advisers from $2 billion to $1.5 billion and require additional reporting regarding fund strategies to improve information available to the SEC and the FSOC; and (3) revise reporting requirements for large liquidity fund advisers to be more consistent with proposed reporting requirements for money market funds to assess short-term funding markets. The changes would impact large hedge fund advisers, private equity advisers and large liquidity fund advisers. The proposed version (Release) states that the changes “are designed to improve the FSOC’s monitoring and assessment of systemic risk” and to “collect additional data for the [SEC]in its regulatory programs. »

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