Form PF

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Form PF

Also called private fund reporting form

Definition

Form PF is a confidential report that SEC-registered investment advisers to private funds file with the SEC, and with the CFTC for dual registrants. It covers fund size, leverage, liquidity, counterparties and investor concentration. Regulators use it to monitor systemic risk from hedge funds, private equity and other private funds.

01 SECTION 1 ALL02 SECTION 2 HEDGE03 SECTION 4 PE04 CURRENT REPORTS
Fig. 1 · Form PF
Advisers Act Rule 204(b)-1 · Form PF current reporting amendments · Form PF amendments 2024
Key rulesAdvisers Act Rule 204(b)-1 · Form PF current reporting amendments · Form PF amendments 2024
Applies toSEC-registered advisers to private funds
RegionsUS
01

How it works

Advisers with at least $150 million in private fund assets file Form PF. Smaller advisers file annually, while large hedge fund advisers file quarterly with more detail. Since 2023, large hedge fund advisers must also file current reports within 72 hours of certain stress events, and private equity advisers report events such as adviser-led secondary transactions quarterly.

The form draws on portfolio, risk and investor data across many funds, so compliance and operations teams build controlled data feeds rather than filling it manually. The SEC and CFTC adopted wide amendments in February 2024. Their compliance date has been pushed back several times and now sits at 1 July 2027 while regulators review a 2026 proposal to scale them back.

Step 1Check thresholdsConfirm private fund assets and filer category.
Step 2Gather fund dataPull size, leverage, liquidity and investor data.
Step 3File on PFRDSubmit through the Private Fund Reporting Depository.
Step 4Monitor eventsWatch for triggers needing a current report.
02

The rules

US · 26 October 2011Advisers Act Rule 204(b)-1Rule 204(b)-1 under the Investment Advisers Act and Form PF

Created Form PF, requiring private fund advisers to report systemic risk data to the SEC and FSOC.

SEC-registered advisers to private funds
US · 3 May 2023Form PF current reporting amendmentsSEC amendments to Form PF on current and quarterly event reporting

Added 72-hour current reports for large hedge fund advisers and quarterly event reports for private equity advisers.

Large hedge fund and private equity advisers
US · 8 February 2024Form PF amendments 2024Joint SEC and CFTC amendments to Form PF

Broad revisions to Form PF content; compliance date extended to 1 July 2027 by a joint rule of 31 August 2026.

Private fund advisers, including CFTC dual registrants
03

Common questions

Who must file Form PF?

SEC-registered investment advisers that manage one or more private funds and have at least $150 million in regulatory assets under management attributable to private funds. Advisers also registered with the CFTC as commodity pool operators or commodity trading advisers can satisfy some CFTC duties through the same form.

Is Form PF public?

No. Form PF is filed confidentially and the data is not published at fund level. Regulators use it for systemic risk monitoring and publish only aggregated statistics. Firms still treat filings as regulatory records subject to examination.

When do the 2024 Form PF amendments apply?

The joint SEC and CFTC amendments adopted on 8 February 2024 now have a compliance date of 1 July 2027. Until then filers may keep using the version of Form PF in effect before the amendments.

How often is Form PF filed?

Large hedge fund advisers file quarterly and large private equity advisers file annually with extra sections. Smaller advisers file annually. Event-driven current reports and quarterly private equity event reports sit on top of the regular cycle.