As private fund compliance officers shake off the work of the most recent Form PF, I decided to finally take a look at what the Securities and Exchange Commission and Commodity Futures Trading Commission are thinking about changing to Form PF. On April 20, the SEC and CFTC proposed amendments to Form PF and its filing requirements.
In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 mandated that the SEC and the CFTC jointly promulgate rules to establish the form and content of private fund reports. Dodd-Frank gave broad parameters on what had to be reported in what is now Form PF. The first set of reforms came two years, but were delayed until October of this year.
What’s on tap for a potential change?
Minimum filing requirements. The SEC and CFTC are proposing to raise the filing threshold for all filers, from $150 million in private fund assets under management to $1 billion. The estimate is that it will eliminate the filing requirement for almost half of the current filers.
Large Hedge Funds. The SEC and CFTC are raise the definition of large hedge fund advisers from $1.5 billion in hedge fund assets under management to $10 billion. That estimate for that is that two-thirds of the current crop of large hedge funds will no longer be “large.”
There are a whole host of other changes. Most of which don’t appear to affect my reporting requirements so I haven’t taken a closer look.
You’ve got 60 days to submit comments.
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