Doug Cornelius on compliance for private equity real estate
The Securities and Exchange Commission and the Commodity Futures Trading Commission extended the compliance date for the February 8, 2024 amendments to Form PF. The compliance date for these amendments was originally March 12, 2025 and has now been extended to June 12, 2025. For annual filers, that means the new requirements won’t kick in … Read more »
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 … Read more »
It’s been a decade since the SEC and FSOC pushed Form PF on to private funds. The SEC has decided it wants more data and has proposed an amendment to Form PF. The big change is next day reporting for key events by Large Hedge Fund Advisers and Private Equity Funds For large Hedge Funds: certain … Read more »
The SEC must have realized that its relief from Form ADV filing and Form PF filing deadlines was not providing much relief. The SEC issued a new order for the deadlines. You still have to send the SEC a notice that your firm is relying on the Order, but you no longer have to say … Read more »
A mentioned two weeks ago that the Securities and Exchange Commission was looking at private fund managers who failed to Form PF. That is now official and the SEC announced enforcement actions against 13 private fund managers. The SEC’s orders are against: Bachrach Asset Management Inc. Biglari Capital LLC Brahma Management Ltd. Bristol Group Inc. … Read more »
With the statutory changes from Dodd-Frank, the Securities and Exchange Commission started gathering basic information about private fund managers and their funds on Form ADV. The SEC increased that information flow by requiring Form PF. Unlike Form ADV, Form PF provides detailed information about the private fund’s activities and performance. That left many reluctant to … Read more »
The Securities and Exchange Commission has been acquiring troves of data about private funds through the Form PF filing requirement. Some, including myself, have been skeptical that the SEC will figure out what to do with the data as a tool to protect investors. But, the SEC has been able to compile statistics and published a … Read more »
If you manage a private fund and are registered with the Securities and Exchange Commission, you spend a good chunk of April (and maybe more) filling out Form PF. Ever wonder what the SEC does with all that data? They publish an annual report on fund statistics, which was recently released. Form PF implemented Section … Read more »
You slave over Form PF trying to get the information demanded by the Securities and Exchange Commission. What happens to that data? The Dodd-Frank Wall Street Reform and Consumer Protection Act Section 404 directed the SEC to establish reporting requirements for investment advisers to private funds as necessary and appropriate in the public interest and … Read more »
If you run a private fund, today is deadline for the annual Form PF filing with the Securities and Exchange Commission. Depending on the type of fund, you have different reporting requirements. The SEC gets bogged down with poor definitions trying to distinguish among the types of funds. In the glossary to Form PF, a … Read more »