IA Compliance: The Full 360° View East 
March 7-8, 2019 | Washington, D.C.

UPCOMING WEBINARS

Conquering Current Compliance Challenges
Feb. 13, 2019 | 2:00 - 2:30 PM EST

Strategies to Make this Year’s Form ADV Update a Breeze
Feb. 19, 2019 | 2:00 - 2:30 PM EST
 
RECORDED WEBINARS

Conquering Current Compliance Challenges
Recorded: January 16, 2019 
  Includes: 23 Best Practices, 5 Peer-tested tools and 15 No Action Letters

The SEC Examinations Priorities Handbook
Includes: 28 Best Practices, 20 Document Request Letters and 6 OCIE Risk Alerts

Cybersecurity Strategies to Ensure SEC Compliance, 2nd Edition
Includes: 24 Best Practices, 16 Tools, 4 Risk Alerts and IM Guidance

 
FORM PF OVERVIEW

Investment Advisers Act rule 204(b)(1) requires SEC-registered advisers with at least $150 million in private fund assets under management to submit periodic reports on Form PF (private fund).  The rule took effect March 31, 2012 and the first Form PF filings were made in July 2012.
 
You must file an updated Form PF:
 

  • At least annually, not later than the date specified in the instructions to Form PF; and
  • More frequently, if required by the instructions.
 
The Form PF seeks the adviser’s identity, AUM, size, leverage and performance of all private funds, gross and net assets and aggregate notional value of its derivative positions, among other detail tied to type of adviser and dependent on how large and diverse their business is.

The SEC’s use of data

The treasure trove of data is used by the SEC for pre-examination due diligence and in risk identification. Examiners’ are looking for trends and possible emerging risks.in the private fund industry. They are also further developing analytics to monitor the risk-taking activities of investment advisers to hedge funds and other private funds.
 
SEC examiners will read an adviser’s Form PF filing before showing up for an exam onsite.  They will look for inconsistencies with other information obtained from an adviser during an examination, such as due diligence reports, pitch books, offering documents, operating agreements and books and records.  Examiners also will look for discrepancies between an adviser’s Form PF filing and its Form ADV.
 
Investment strategies highlighted in the data that don’t match disclosures also will catch an examiner’s eye.  Form PF data also may wave red flags that trigger an exam based on exposures, valuation, high-frequency trading and aberrational returns.

Still have questions? Click here to share your questions with our editors.

© 2019 Simplify Compliance. ALL RIGHTS RESERVED | PRIVACY POLICY | TERMS & CONDITIONS | ABOUT US | CONTACT US