Form PF is the confidential report that SEC-registered investment advisers to private funds must file when they manage at least $150 million in private fund assets, and the Form PF filing requirements set who files, how often, and what data goes in based on the size and type of funds an adviser runs. The form feeds the Securities and Exchange Commission, the Commodity Futures Trading Commission, and the Financial Stability Oversight Council data on fund size, leverage, strategy, investor concentration, and risk exposures so those agencies can monitor systemic threats. Recent amendments, with compliance dates running through 2025 and 2026, added event-based triggers and expanded the data every filer must provide.
Who Has to File
Three conditions must all be met. The adviser is registered, or required to be registered, with the SEC under the Investment Advisers Act of 1940; it advises at least one private fund; and it managed at least $150 million in private fund assets as of the end of its most recently completed fiscal year.1eCFR. 17 CFR 275.204(b)-1 – Reporting by Investment Advisers to Private Funds Advisers below the $150 million mark are generally exempt.
The threshold is measured against total regulatory assets under management across all private funds the adviser advises, at gross asset value without netting out liabilities. Master-feeder and parallel fund structures are aggregated; dependent parallel managed accounts are combined with the largest related private fund; and the adviser must count private funds managed by a related person that is not separately operated.2U.S. Securities and Exchange Commission. Form PF Frequently Asked Questions
Filer Categories and Deadlines
Form PF sorts filers into four categories. The category drives both the depth of the report and the filing frequency.
Small private fund advisers manage at least $150 million in private fund assets but fall below the large-adviser thresholds. They file annually, within 120 calendar days after fiscal year-end.3Securities and Exchange Commission. Form PF Reporting Form for Investment Advisers to Private Funds
Large hedge fund advisers manage at least $1.5 billion in hedge fund assets as of the last day of any month in the preceding fiscal quarter. They file quarterly, within 60 calendar days after each quarter ends.3Securities and Exchange Commission. Form PF Reporting Form for Investment Advisers to Private Funds
Large liquidity fund advisers manage at least $1 billion in combined money market fund and liquidity fund assets. They file quarterly, within 15 calendar days after each quarter ends.3Securities and Exchange Commission. Form PF Reporting Form for Investment Advisers to Private Funds
Large private equity fund advisers manage at least $2 billion in private equity fund assets as of the last day of their most recently completed fiscal year. They file annually, within 120 days of fiscal year-end, and also submit quarterly event reports when specific triggers occur.4Federal Register. Form PF Event Reporting for Large Hedge Fund Advisers and Private Equity Fund Advisers
Large hedge fund advisers and large liquidity fund advisers file only quarterly. They do not submit a separate annual update.3Securities and Exchange Commission. Form PF Reporting Form for Investment Advisers to Private Funds
The Shift to Calendar-Quarter Reporting
Amendments adopted in 2024 moved quarterly reporting from a fiscal-quarter basis to a calendar-quarter basis. Any filing made on or after October 1, 2025, must use the amended form, and all quarterly filers transition to calendar-quarter reporting for the quarter ending December 31, 2025. The first calendar-quarter filing under the amended form is due by March 1, 2026.2U.S. Securities and Exchange Commission. Form PF Frequently Asked Questions
How Form PF Classifies Fund Types
Whether a fund counts as a hedge fund, liquidity fund, or private equity fund determines which sections and deadlines apply. The definitions on Form PF are specific and may not match everyday industry usage.
A private fund is a hedge fund for Form PF purposes if any one of three tests is met: the adviser can collect a performance fee based on unrealized gains; the fund can borrow more than half its net asset value or carry gross notional exposure exceeding twice its net asset value; or the fund can sell securities short, other than to hedge currency or manage duration. Any commodity pool reported on Form PF is also classified as a hedge fund.5Securities and Exchange Commission. Form PF Reporting Form for Investment Advisers to Private Funds – Glossary of Terms
A liquidity fund is one that seeks to maintain a stable net asset value per unit, similar to a money market fund. A private equity fund is generally any private fund that is not a hedge fund, liquidity fund, real estate fund, securitized asset fund, or venture capital fund. Under the 2024 amendments, filers now pick the fund type from a defined list that includes these categories plus “other.”6Federal Register. Form PF Reporting Requirements for All Filers and Large Hedge Fund Advisers
What the Form Asks For
Form PF is divided into sections keyed to adviser categories. Every filer completes Section 1, which collects identifying information about the adviser and basic data on the private funds it manages, including fund type, size, borrowing, strategy, investor concentration, and performance. The 2024 amendments expanded Section 1 to include whether a fund is open-end or closed-end, whether it operates as a UCITS or AIF, details about trading vehicles, and the fund’s base currency.6Federal Register. Form PF Reporting Requirements for All Filers and Large Hedge Fund Advisers
Additional sections apply to larger advisers. Section 2 asks large hedge fund advisers for detailed information on each qualifying hedge fund, including counterparty exposures, position concentrations, and risk metrics. Section 3 asks large liquidity fund advisers for portfolio composition and investor concentration data on each liquidity fund. Section 4 asks large private equity fund advisers for information about portfolio companies, leverage, and fund-level financial details.3Securities and Exchange Commission. Form PF Reporting Form for Investment Advisers to Private Funds
Valuation Standards
All investments reported on Form PF must be valued at market value when a market price is readily available. When no market price exists, the adviser uses fair value. For annual or fourth-quarter filings, advisers categorize assets and liabilities under a three-level fair value hierarchy similar to U.S. GAAP: Level 1 covers quoted prices in active markets, Level 2 covers observable inputs other than quoted prices, and Level 3 covers unobservable inputs such as the adviser’s own assumptions. If a fund’s audit is not complete when the filing is due, the adviser may use estimated values and note that they are estimates.3Securities and Exchange Commission. Form PF Reporting Form for Investment Advisers to Private Funds
Event Reporting
Alongside the periodic filings, Form PF now requires faster reports when specific stress events occur. The current-reporting requirements took effect on December 11, 2023.4Federal Register. Form PF Event Reporting for Large Hedge Fund Advisers and Private Equity Fund Advisers
72-Hour Reports for Large Hedge Fund Advisers
A large hedge fund adviser must file a current report within 72 hours of certain events at any qualifying hedge fund it manages, meaning a hedge fund with a net asset value of at least $500 million.6Federal Register. Form PF Reporting Requirements for All Filers and Large Hedge Fund Advisers The triggers are:
- Extraordinary investment losses: a rolling 10-business-day return of negative 20 percent or worse of the fund’s aggregate calculated value.7SEC.gov. Form PF Event Reporting for Large Hedge Fund Advisers and Private Equity Fund Advisers
- Significant margin increases: margin, collateral, or equivalent amounts rising by 20 percent or more of the fund’s average daily value over a rolling 10-business-day period.
- Margin default: the fund fails to meet a margin call, even after any contractual cure period.
- Counterparty default: a counterparty fails to meet payment obligations and the amount exceeds five percent of the fund’s aggregate calculated value.
- Loss of a prime broker: a prime broker terminates or materially restricts its relationship with the fund.
- Operations disruption: a significant disruption or degradation of critical operations for trading, valuation, risk management, or compliance with federal securities laws.
- Large redemption requests: cumulative withdrawal or redemption requests exceeding 50 percent of the fund’s most recent net asset value, net of new subscriptions.
- Inability to satisfy redemptions: the fund cannot pay redemption requests or suspends redemptions for more than five consecutive business days.7SEC.gov. Form PF Event Reporting for Large Hedge Fund Advisers and Private Equity Fund Advisers
Quarterly Event Reports for Large Private Equity Fund Advisers
A large private equity fund adviser must file an event report within 60 days after the end of a fiscal quarter in which a reportable event occurs. Two categories trigger reporting: the closing of an adviser-led secondary transaction, or investors removing the adviser (or an affiliate) as general partner, electing to terminate the fund’s investment period, or electing to terminate the fund itself.8Securities and Exchange Commission. Form PF Reporting Form for Investment Advisers to Private Funds – Section 6
How to File and What It Costs
Form PF is filed electronically through the Private Fund Reporting Depository, a system housed on the Investment Adviser Registration Depository (IARD) and operated by FINRA.1eCFR. 17 CFR 275.204(b)-1 – Reporting by Investment Advisers to Private Funds Before an adviser can access the system, the firm designates a Super Account Administrator, typically the Chief Compliance Officer or Additional Regulatory Contact listed on Form ADV, who then receives login credentials from FINRA.9FINRA. FINRA Entitlement Program Frequently Asked Questions
Each initial filing and each periodic update carries a $150 filing fee. Quarterly filers pay that fee four times a year, annual filers pay once, and amendments to a previously filed report are free.10IARD. Welcome to the Private Fund Reporting Depository If unanticipated technical problems prevent a timely electronic filing, the adviser may request a temporary hardship exemption by submitting a paper filing within one business day and an electronic version within seven business days.1eCFR. 17 CFR 275.204(b)-1 – Reporting by Investment Advisers to Private Funds
Confidentiality and Penalties
The Dodd-Frank Act imposes heightened confidentiality on Form PF data. What advisers report is generally treated as non-public, and federal law restricts how the SEC, CFTC, and FSOC may share it. Sharing is generally tied to assessing systemic risk or use in enforcement or judicial proceedings.11SEC.gov. Form PF Presentation
Missing a filing is a violation of the Investment Advisers Act. In December 2024, the SEC charged seven private fund advisers with repeatedly failing to file Form PF on time. The advisers agreed to cease-and-desist orders, censures, and civil monetary penalties totaling $790,000, and each remediated its past failures by completing the missing filings during the investigation.12U.S. Securities and Exchange Commission. SEC Charges Seven Private Fund Advisers for Repeatedly Failing to File Form PF An adviser that expects to miss a deadline because of technical problems should request the temporary hardship exemption rather than file late.