Many private funds struggled with getting Form PF filed. Many in fund compliance were dubious that the Securities and Exchange Commission would be able to do anything meaningful with the massive amount of data pushed through the form. Regardless, Section 404 of Dodd-Frank required the SEC to gather the data so the Financial Stability Oversight … Read more »
Tag: Form PF
Borrowings and Form PF
A question popped up during a meeting of some real estate compliance folks talking about Form PF. How do you treat subsidiary mortgage borrowings? Question 12(a) asks for the dollar amount of borrowings for the fund. Two main issues came into play: write-downs and recourse. As many real estate funds are still recovering from the … Read more »
Gathering Information on Your Private Fund Investors
One item that I picked up from PEI’s recent Private Fund Compliance Conference is the new way you need gather information about investors in your private fund for Form PF. I put Form PF to the side because my filing is not required until next year. However, there is a key March 31, 2012 date … Read more »
Update on the new regulations and how they will impact you going forward
These are my notes from the “Update on the new regulations and how they will impact you going forward” session at the Private Fund Compliance Forum 2012. Excuse the typos and rambling nature. They are just my raw notes. Moderator: Karen Barr, General Counsel, Investment Adviser Association Panel Members: Jason E. Brown, Partner, Ropes & … Read more »
Real Estate Funds and Form PF
In addition to filing Form ADV with the SEC when they register with the Securities and Exchange Commission, private fund managers will also need to start filing Form PF. I received a helpful reminder about this last week form SEC’s IARD system. (I’ll need to get used to messages with the subject line: “Firm 158137: … Read more »
Form PF and Private Funds
IN addition to filing Form ADV with the SEC when they register with the Securities and Exchange Commission, private fund managers will also need to start filing Form PF next year. The amount of information required by Form PF is tiered. Advisers managing less than $150 million in private funds are not required to file, … Read more »
The SEC Wants to Know if You Are Systemically Important
The Securities and Exchange Commission proposed a new rule that would require advisers to private funds to report information for use by the Financial Stability Oversight Council in monitoring risk to the U.S. financial system. Sections 404 and 406 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires the SEC to gather this … Read more »