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Form PF is a key regulatory filing that private fund advisers must submit to the U.S. Securities and Exchange Commission (SEC). Designed to enhance oversight and risk management, Form PF provides essential data that helps the SEC and the Financial Stability Oversight Council (FSOC) monitor private fund activities and systemic risks.
If you are an SEC-registered investment adviser managing private funds with assets under management (AUM) exceeding $150 million, filing Form PF is a requirement. This obligation extends to Commodity Pool Operators (CPOs) and Commodity Trading Advisors (CTAs) registered with the Commodity Futures Trading Commission (CFTC).
Important update: New Form PF requirements take effect June 12, 2025, bringing significant implications for all managers.
Navigating Form PF can be complex, and compliance with SEC and CFTC requirements is critical. At IQ-EQ, we simplify the process, ensuring your filings are accurate, timely, and aligned with regulatory standards. Our expert team provides:
- End-to-end support for Form PF preparation and submission.
- Regulatory expertise to ensure compliance with evolving SEC and FSOC requirements.
- Customized guidance for large fund reporting, tailored to your firm’s needs.
What is Form PF?
Form PF is a regulatory filing required by the U.S. Securities and Exchange Commission (SEC) for certain private fund advisers. It provides data to the SEC and the Financial Stability Oversight Council (FSOC) to help monitor systemic risk in private funds.
Who needs to file Form PF?
You must file Form PF if you meet the following criteria:
- You are registered with the SEC as an investment adviser or with the CFTC as a Commodity Pool Operator (CPO) or Commodity Trading Advisor (CTA)
- You advise at least one private fund (e.g., hedge funds, private equity, venture capital)
- You manage at least $150 million in private fund assets under management (AUM) as of the end of your most recent fiscal year
When is Form PF due?
The frequency of filing depends on the size of the adviser:
- Most advisers must file annually within 120 days of fiscal year end with the exception of the below:
- Large Hedge Fund Advisers – report within 60 days after the end of each quarter if assets under management are greater than $1.5 billion as of the last day of any month in the fiscal quarter immediately preceding your most recently completed fiscal quarter
- Large Liquidity Fund Advisers – report within 15 days after the end of each quarter if your combined money market and liquidity fund assets under management are greater than $1 billion as of the last day of any month in the fiscal quarter immediately preceding your most recently completed fiscal quarter
- Large Hedge Fund Advisers must also file Section 5 within 72 hours after occurrence of an applicable trigger event
- Private Equity Fund Advisers must also file Section 6 within 60 calendar days after quarter-end of an applicable trigger event
What information is required in Form PF?
Filers must report key details about their private funds, including (but not limited to):
- Fund structure (master-feeder or parallel funds)
- Gross asset value (“GAV”) and Net Asset Value (“NAV”) for each private fund
- Investment strategy and portfolio holdings/activity
- Withdrawal and redemption activity
- Unfunded commitments and contributions
- Leveraging activity and balances
- Performance returns (IRR or gross/net total return)
- Counterparty exposure (borrowing, lending collateral, derivatives)
- Investor breakdown that includes account balances and type