Form PF 101:

Author:

Jordan Dague
Product Manager, Confluence

On June 12, private fund advisers will face significant new reporting requirements under the SEC's latest Form PF amendments. These changes, announced last February, require disaggregated reporting on master-feeder and parallel fund structures, introduce new "trading vehicle" concepts, and significantly change how complex fund structures report their operations.

Form PF, although not very old, has been subject to frequent revisions. This marks the third major amendment to Form PF since May 2023, following changes requiring hedge fund advisers to report certain triggering events within 72 hours and aligning liquidity fund reporting with money market fund requirements.

With the compliance deadline fast approaching, asset managers should view the SEC’s expanded reporting requirements as an opportunity to strengthen their operational infrastructure and compliance capabilities with system upgrades and new technology. Tools such as Confluence’s Omnia can solve some of the biggest challenges firms face through efficient data processing and reconciliation abilities.

Here we look at common questions about the new Form PF.

What is SEC Form PF?

For asset managers, Form PF represents more than just another regulatory filing. It's a comprehensive reporting framework that requires detailed disclosure of a fund's investment strategies, leverage positions, counterparty risk exposure, and trading practices. The 2024 amendments significantly expand reporting obligations, particularly around complex fund structures and investment vehicles. Of particular importance to portfolio managers and compliance teams is the new requirement to disaggregate reporting for master-feeder arrangements and parallel fund structures, which moves away from the previous aggregate reporting format.

Who is required to file Form PF?

The filing requirements are threshold-based and vary by fund type. A firm must file if it’s an SEC or CFTC-registered investment adviser managing private funds with at least $150 million in AUM between the entity and any related persons. The 2024 amendments introduced important changes to how these thresholds are calculated, particularly for fund-of-funds structures and complex investment vehicles. Large hedge fund advisers managing $1.5 billion or more, large private equity advisers managing $2 billion or more, and large liquidity fund advisers managing $1 billion or more in combined money market and liquidity fund assets face additional reporting obligations. The new amendments require inclusion of investments in other private funds and related parties when calculating these thresholds.

When are the filing deadlines?

The new requirements take effect June 12, 2025, with different fund types facing varying reporting frequencies. Large hedge fund advisers must file quarterly within 60 days of quarter-end, with 72-hour reporting for specified triggering events such as extraordinary investment losses, large withdrawals and redemptions and counterparty defaults. Large liquidity fund advisers (private funds similar to money market funds but exempt from certain SEC rules governing registered money market funds) face tighter deadlines, requiring quarterly filings within 15 days of quarter-end. Large private equity advisers must submit quarterly reports within 60 days of quarter-end, with additional event-based reporting requirements. Other private fund advisers maintain annual filing requirements within 120 days of fiscal year-end.

What new information must be reported?

The latest amendments substantially expand reporting requirements across several key areas that impact operational processes. Complex fund structures now require separate reporting for master-feeder arrangements and parallel fund structures. New trading vehicle reporting applies to entities holding assets or conducting trading activities. Hedge funds investing in digital assets face enhanced disclosure requirements, while all funds must provide more detailed reporting on prime broker relationships and leverage. Investment strategies must be broken down into more granular detail, including specific exposure and position concentration information.

Looking Ahead

Every change to Form PF paradoxically makes further change more likely. The SEC has made clear that it sees Form PF as a comprehensive regulatory tool reflecting the agency’s increasing focus on private fund oversight. Asset managers should approach these changes as an opportunity to enhance their reporting and risk monitoring capabilities. With proper planning and the right technology, firms can turn these new requirements into an opportunity to strengthen their overall operational frameworks. For compliance teams, establishing robust data quality and reconciliation processes, maintaining accurate reporting for complex structures, and ensuring timely reporting across all required timeframes will be important for long-term compliance success. Reach out to Confluence to learn how we can help.

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