Skip to content

Compliance Building

Doug Cornelius on compliance for private equity real estate

Menu
  • Home
  • About
    • About
    • About Doug
    • About This Website
    • Why I Blog
    • Speaking Engagements
    • Contact
    • Publications
  • Archives
    • Topic Archive
    • Book Reviews
    • Most Popular
  • Subscribe
  • Disclaimers
    • Disclaimers
    • Policies and Procedures
    • Use of Site Content
    • Comments
    • FTC Disclosure
Menu
form pf and sec logo

Nabbing RIAs to Private Funds Who Do Not File Form PF

Posted on December 16, 2024December 13, 2024 by Doug Cornelius
Print Friendly, PDF & Email

Private fund advisers managing $150 million or more of assets have been required to make annual filings on Form PF since 2012. (More often in some cases.) It’s really easy for the Securities and Exchange Commission to match the Form ADV data listing private funds to the Form PF filings for those funds. And it should be just as easy to find those firms who list private funds on Form ADV but didn’t file Form PF for those funds.

The SEC nabbed seven firms that failed to file Form PF for several years. The firms had to pay fines ranging from $90,000 to $150,000. It wasn’t clear why there was a relatively broad range of fines. Size of the firm? Size of the fund? There was no reason to find fraud or malice.

“The SEC uses information collected on Form PF in its regulatory programs, including examinations, investigations and investor protection efforts relating to private fund advisers.  The SEC publishes quarterly reports with aggregated information and statistics derived from Form PF data to inform the public about the private fund industry.  It also provides Form PF data to the Financial Stability Oversight Council to help it evaluate systemic risks posed by hedge funds and other private funds.”

Sources:

  • SEC Charges Seven Private Fund Advisers For Repeatedly Failing To File Form PF
  • Order – Greenhaven Road Investment Management, LP
  • Order – Kudu Investment Holdings, LLC
  • Order – GSSG Solar, LLC
  • Order – Longpoint Partners LP
  • Order – WPAM Advisers LLC
  • Order – NFC Investments, LLC
  • Order – The Catalyst Capital Group Inc.
  • Form PF

Share this:

  • Print (Opens in new window) Print
  • Share on Facebook (Opens in new window) Facebook
  • Share on LinkedIn (Opens in new window) LinkedIn
  • Share on X (Opens in new window) X
  • Email a link to a friend (Opens in new window) Email

Leave a ReplyCancel reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Search for Stuff

Recent Stories

  • California’s Fair Investment Practices by Venture Capital Companies
  • Compliance Bricks and Mortar for January 30
  • Interpreter Insider Trading
  • Things not to put in Advisory Contracts – Hedges
  • Weekend Reading: Bad Company
  • Things to Not Put in an Advisory Agreement – Assignment Rights
  • Congressional Stock Trading and Private Insider Trading
  • Model Fees Versus Actual Fees in Marketing
  • Compliance Bricks and Mortar for January 16
  • Staff Report on Capital-Raising Dynamics

Fight Cancer

Please support my Pan-Mass Challenge
Make a donation to fight cancer. donate.pmc.org/DC0176
pan-mass challenge badge

I am a lawyer, but I am not your lawyer. Since I’m a lawyer, this website may be considered attorney advertising under the ethical rules of certain jurisdictions. Please read my disclaimers page before taking any action. And then, don't take any action based on what I wrote.

Creative Commons logo with the text 'Some Rights Reserved' and three symbols representing attribution, non-commercial use, and share alike.

Compliance Building - by Doug Cornelius is licensed under a Creative Commons Attribution-Noncommercial 3.0 United States License.