The FORM PF is a regulatory reporting requirement whereby hedge fund managers (that are registered with the SEC) with at least $150 million under management must file a FORM PF periodically. Depending on the size of the managers (Assets Under Management) AuM they must file either quarterly or annually. AuM is defined in this instance as “Regulatory Assets Under Management (RAuM)” which is effectively gross assets with no deductions for short sales, borrowings or other forms of leverage.

Advisers are further divided in two according to size. Firstly “Large Private Advisers” are (1) hedge fund advisers with at least $1.5 billion in RAuM in hedge funds, (2) Liquidity fund advisers with at least $1 billion in RAuM attributable to liquidity funds and registered money market funds. (3) advisers with at least $2 billion in RAuM attributable to private equity funds. Large hedge fund advisers are required to file the Form PF within 60 days of the end of each fiscal quarter. Large liquidity fund advisers must file within 15 days of the end of each fiscal quarter. Large private equity fund advisers must file Form PF annually within 120 days of the end of the fiscal year.

The second category contains registered investment advisers who do not meet the criteria above i.e. RAuM < $1.5bn, and are thereby deemed “Smaller Private Advisers”. Smaller Private Advisers only need file annually within 120 days after their fiscal year end and only need to complete Part 1 of the Form PF.

COOConnect had an interesting angle a while back suggesting regulators might cross check reporting from different jurisdictions:

“It is highly probable that the SEC will demand data not just from Form PF, but also from Form CPO-PQR, which is submitted to the National Futures Association (NFA), a self-regulatory body and then passed onto the Commodity Futures Trading Commission (CFTC), and from the Annex IV reports submitted to European regulators under the Alternative Investment Fund Managers Directive (AIFMD). This is despite rising anxiety in Europe about the security as well as the purposes to which American regulators apply European data. The SEC may even ask to look at data reported to investors via Open Protocol Enabling Risk Aggregation (“Open Protocol,” formerly known as OPERA), the risk reporting toolkit developed by Albourne Partners.”

And COOConnect conclude:

“It follows that fund managers must ensure overlapping data points contained in these multi-jurisdictional and multi-agency reporting documents are consistent, or it will invite further scrutiny. That means checking RAuM numbers, notional values of derivatives, counterparty risks and portfolio exposures to ensure they are reported consistently to all regulators.”

RiskSystem clients are taking comfort that their multi-jurisdictional regulatory reporting is emanating from a single source in a consistent manner thus reducing their regulatory and hence business risk.

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