US – Form PF Reporting – Highwire Extensions

Introduction to Form PF Reporting

Form PF came into effect from 31st March 2012 and requires investment advisers registered with the SEC that advise one or more “private funds” to file Form PF with the SEC.

Timings and Frequencies differ, but for “Large Hedge Fund Advisers” it is quarterly reporting within 60 calendar days from the quarter ends. Reporting can be cumbersome. It involves a range of calculations and the data is likely to be sourced from multiple systems, administrators, Portfolio Managers, Portfolio Companies and third parties.

Who Form PF applies to

You must complete and submit a Form PF if:

You are registered or are required to register with the SEC as an investment adviser, or you are registered or required to register with the Commodity Futures Trading Commission (CFTC) as a commodity pool operator or commodity trading advisor and you are also registered or required to register with the SEC as an investment adviser; and
You manage one or more private funds; and
You and your related persons, collectively, had at least $150 million in private fund assets under management as of the last day of your most recently completed fiscal year.

“Private funds” refers to issuers exempt from registration under the Investment Company Act of 1940 Sections 3(c)(1) or Section 3(c)(7). It includes private equity, hedge funds and liquidity funds.

SECTION	INFORMATION REQUIRED	TOTAL QUESTIONS	APPLICABLE TO	REPORT IN RESPECT OF
*Qualifying hedge funds are individual funds with greater than $500m AUM.
SECTION 1A	Information about Fund and Related Persons	4	All Private Fund Advisers	All Private Funds
SECTION 1B	Information about the advising Fund	12	All Private Fund Advisers	All Private Funds
SECTION 1C	Information about the Hedge Fund you advise	9	All Private Fund Advisers managing 1 or more hedge funds	Each Hedge Fund
SECTION 2A	Aggregated Information about the Hedge Fund	3	Large hedge fund advisers	Each Large Hedge Fund
SECTION 2B	Information about Qualifying Hedge Funds	22	Large hedge fund advisers	Each Qualifying Hedge funds*
SECTION 3	Information about the Liquid Fund you advise	14	Large liquidity fund advisers	Each Large Liquid Fund
SECTION 4	Information about the Private Equity Fund you advise	15	Large Private Equity Fund Advisers	Each Large Private Equity Funds
SECTION 5	Request for temporary hardship exemption	6	All Private Fund Advisers – (if applicable)	Each Private Funds

“large hedge fund adviser” – greater than $1.5 billion in hedge fund assets under management
“large liquidity fund adviser” – greater than $1 billion
“large private equity fund adviser” – greater than $2 billion in private equity fund assets under management

Further detail is set out in the table below:

	FUND	ADVISER
Hedge Fund	A hedge fund is any private fund, excluding a securitised asset fund that: Pays a performance fee to an adviser taking into account market value May borrow an amount in excess of one-half of its net asset Has gross notional exposure in excess of twice its net asset value Sells securities or other assets short	Large Hedge Fund Adviser A threshold of $1.5 billion in hedge fund assets under management to be considered a “large hedge fund adviser”
Liquid Fund	A liquid fund is a private fund that: seeks to generate income by investing in a portfolio of short term obligations in order to maintain a stable net asset value per unit or minimize principal volatility for investors.	Large liquid Fund Adviser A threshold of $1 billion to be considered a “large liquidity fund adviser”. With respect to any adviser, liquidity fund assets under management are the portion of such adviser’s regulatory assets under management that are attributable to liquidity funds it advises
Private Equity Fund	A private equity fund is any private fund that: is not a hedge fund, liquidity fund, real estate fund, securitized asset fund or venture capital fund; and does not provide investors with redemption rights in the ordinary course.	Large Private Equity Fund Adviser $2 billion in private equity fund assets under management to be considered a “large private equity fund adviser”, With respect to any adviser, private equity fund assets under management are the portion of such adviser’s regulatory assets under management that are attributable to private equity funds it advises.

FUND

ADVISER

Hedge Fund

A hedge fund is any private fund, excluding a securitised asset fund that:

Pays a performance fee to an adviser taking into account market value
May borrow an amount in excess of one-half of its net asset
Has gross notional exposure in excess of twice its net asset value
Sells securities or other assets short

Large Hedge Fund Adviser

A threshold of $1.5 billion in hedge fund assets under management to be considered a “large hedge fund adviser”

Liquid Fund

A liquid fund is a private fund that:

seeks to generate income by investing in a portfolio of short term obligations in order to maintain a stable net asset value per unit or minimize principal volatility for investors.

Large liquid Fund Adviser

A threshold of $1 billion to be considered a “large liquidity fund adviser”. With respect to any adviser, liquidity fund assets under management are the portion of such adviser’s regulatory assets under management that are attributable to liquidity funds it advises

Private Equity Fund

A private equity fund is any private fund that:

is not a hedge fund, liquidity fund, real estate fund, securitized asset fund or venture capital fund; and
does not provide investors with redemption rights in the ordinary course.

Large Private Equity Fund Adviser

$2 billion in private equity fund assets under management to be considered a “large private equity fund adviser”,
With respect to any adviser, private equity fund assets under management are the portion of such adviser’s regulatory assets under management that are attributable to private equity funds it advises.

ADVISERS AND FUND TYPE	REPORTING FREQUENCY	REPORTING DEADLINE
Small Private Fund Advisers above $150 million and other Registered Private Fund Advisers*	Annually	120 calendar days from Fiscal quarter closing
Large Hedge Fund Advisers	Quarterly	60 calendar days from Fiscal quarter closing
Large Liquid and Money Market Advisers	Quarterly	15 calendar days from Fiscal quarter closing

LEGISLATION AND GUIDELINES

GUIDELINES

THE FORM

TYPES OF ADVISERS AND FUNDS – MORE DETAIL

REPORTING FREQUENCY AND DEADLINES

COMPLETING THE FORM

FILING

COMPARISON TO AIFMD ANNEX IV

FUNDS-AXIS MANAGED SERVICE