Form PF — Systemic Risk Reporting
What It Is
Form PF is a confidential reporting form filed with the SEC by investment advisers to private funds. It was created under the Dodd-Frank Act to help regulators monitor systemic risk in the private fund industry. The Financial Stability Oversight Council (FSOC) uses the data.
Form PF is filed through the SEC’s IARD/PFRD system.
Who Must File
Form PF is required for SEC-registered investment advisers that manage one or more private funds and have at least $150 million in private fund assets under management (AUM).
Key Thresholds
| Category | AUM Threshold | Filing Frequency | Deadline |
|---|---|---|---|
| Smaller private fund adviser | $150M+ | Annually | 120 days after fiscal year-end |
| Large hedge fund adviser | $1.5B+ in hedge fund AUM | Quarterly | 60 days after quarter-end |
| Large liquidity fund adviser | $1B+ in liquidity fund AUM | Quarterly | 15 days after quarter-end |
| Large private equity adviser | $2B+ in PE fund AUM | Annually | 120 days after fiscal year-end |
Current event reporting (added 2024)
Large hedge fund advisers must also report certain events within 72 hours:
- Extraordinary investment losses (20%+ decline in a rolling 10-day period)
- Significant margin/default events
- Large counterparty defaults
- Large withdrawal/redemption requests
Exempt Reporting Advisers
ERAs are not required to file Form PF. The filing obligation applies only to SEC-registered advisers.
How It Applies to Palace Fund
Most Likely Scenario: No Filing Required
If Palace Fund’s manager:
- Operates as an exempt reporting adviser (ERA), OR
- Is SEC-registered but manages less than $150 million in private fund AUM
Then Form PF filing is not required.
If the Fund Grows Past $150M AUM
If the manager becomes SEC-registered and AUM exceeds $150 million:
- Annual Form PF filing becomes required
- Must report basic information: fund size, leverage, investor types, asset classes, performance
- Filing is confidential (not publicly available)
What Form PF Section 1 Covers (for smaller filers)
- Adviser and fund identifying information
- AUM and net asset value
- Borrowing and counterparty exposure
- Investor information (types, concentration)
- Fund performance
- Investment strategies and asset types
Costs and Burden
- For a small fund below thresholds: No cost (no filing required)
- **For a fund that crosses 5,000 to $20,000 per filing, typically handled by outside compliance consultants or fund administrators
Action Items
- Confirm registration status: If operating as an ERA, Form PF does not apply.
- Monitor AUM growth: If the fund approaches $150 million and the manager is SEC-registered, prepare for Form PF filing obligations.
- Keep records that support Form PF data: Even if not currently required to file, maintain records of fund AUM, leverage, investor types, and performance. These are useful for other regulatory purposes and will be needed if Form PF filing is triggered.
- Engage a compliance consultant before the threshold: If approaching $150M, engage a compliance firm experienced with Form PF at least 6 months before the expected filing date.
Key Takeaway
Form PF is not a concern for a small fund operating as an ERA or managing under 150 million threshold. No filing is required until then, but maintaining clean records now will make future compliance easier.