Form PF (private fund) is a new SEC rule that requires private fund advisers to report regulatory assets under management, dubbed RAUM, to the Financial Stability Oversight Council (FSOC), an organization established under Dodd-Frank in order to monitor risks within the financial sector.
The Form PF requirements are intended to provide risk exposure statistics regarding the type and size of assets held by private fund firms. A part of the Dodd Frank Act, the Form PF rule officially went into effect on June 15, 2012. The SEC, the CFTC and the FSOC are overseeing the implementation of regulation.
Since its enactment, all investment advisers, commodity pool operators and commodity trading advisers (CTAs) registered with the SEC with at least $150 million in private funds under management must periodically file Form PF. All private funds with assets under $150 million are not required to file the document.
The frequency of reporting required of the private fund (PF) advisers depends on the size of the fund. The two main categories are large private fund advisers and small private fund advisers.
The large private fund advisers’ category includes: those with at least $1.5 billion in AUM; liquidity fund advisers with at least $1 billion in combined assets; and advisers with at least $2 billion in AUM in private equity funds. All other advisers are categorized as small private fund advisers.
As of now, most private fund advisers are in the small private funds category and they are only required to file Form PF annually and to provide basic information about their funds.
Large private fund advisers, on the other hand, are required to report more information more frequently depending on the type of funds they oversee. Although the majority of private fund advisors are small private fund advisors, large private fund advisors represent the majority of the industry’s assets under management.
In addition, most large private equity firms will have to file Form PF within 15 days of the end of each fiscal quarter. Therefore, most private fund advisors anticipate that they will file Form PF at the end of their first fiscal quarter, or after Dec. 15, 2012.