The Form PF Filing Process – Highwire Extensions

All Form PFs are filed online through the PFRD (Private Fund Reporting Depository) system. PFRD is a sub-system of the IARD system

Since 2001, investment advisers register and submit filings to the SEC through the Investment Adviser Registration Depository (IARD) electronic filing system. The IARD was built and is operated by the Financial Industry Regulatory Authority (FINRA). FINRA does not have regulatory authority over Investment Advisers; however, it was chosen to develop, operate, and maintain the system because of its regulatory business and technical expertise. IARD provides regulators with the ability to monitor and process Investment Adviser information via a single, centralized system.

Below is some key information:

METHODS OF FILING

Form PF may be filed either through:

Manually entering information in a web-based form;
XML batch filings; and
Machine-to-machine XML filings

See below for more on filing types and on the Web Services accounts.

TYPES OF FILING

There are 5 different types of filing. The standard filing is the “Updating” which is the annual or quarterly submission.

INITIAL	You are not a large hedge fund adviser or large liquidity fund adviser. Submit your first Form PF Annual Filing for the period ended: mm/dd/yyyy or You are a large hedge fund adviser or large liquidity fund adviser. Submit your first Form PF Quarterly Filing for the period ended: mm/dd/yyyy	Choose this filing type to submit your Initial Form PF filing. For advisers filing Form PF for the first time, only these two filing options will display. The Initial filing is intended to only be submitted once. After an adviser submits their Initial filing, data for subsequent reporting periods should be filed using the Updating filing type.
UPDATING	Submit a Form PF Annual Update filing for the period ended: mm/dd/yyyy or Submit a Form PF Quarterly Update filing for the period ended: mm/dd/yyyy	Choose this filing type to submit your annual or quarterly Form PF Update filing. The system will display the Annual or Quarterly Update filing option based on the adviser’s Initial or Transition (if applicable) Form PF filing.
AMENDMENT	Submit a Form PF Amendment to a previously submitted PF filing for the period ended: mm/dd/yyyy	Choose this filing type to edit fund information previously submitted via Form PF for a particular reporting period. Also use this filing type when reporting on additional funds for a previously submitted reporting period end date.
TRANSITION	Transition to Annual Reporting	Choose this filing type to notify the SEC of your transition from Quarterly to Annual reporting. This filing type is only a notification that your firm will now be reporting annually, so it does not contain any fund data. (Note: In the opposite scenario of transitioning from Annual to Quarterly, no additional Transition filing is needed. You would simply begin filing with the next quarter.)
FINAL	Submit a Form PF Final Filing	Choose this filing type if your firm is no longer required to submit Form PF and this is will be your last Form PF filing. This filing type contains no fund data, so any necessary Update or Amendment filings should have already been submitted prior to your Final filing.

QUERIES

OTHER USEFUL INFORMATION

PFRD WEB SERVICE ACCOUNTS (CREATE ACCOUNT OR MODIFY ACCESS)

Firms that choose to submit Form PF filings via data file transfer (i.e., machine-to-machine) are able to establish a Web Services account with FINRA for this purpose. To do so, firms are now required to telephonically request from FINRA a PFRD Web Services Entitlement Form (Entitlement Form). This form is no longer publicly available. To obtain this form, an Authorized Signatory of your organization must contact the IARD Call Center at (240) 386-4848. An Authorized Signatory is

defined as the Chief Compliance Officer (CCO) or Additional Regulatory Contact (ARC) listed on your firm’s current Form ADV.

Preliminary Activities

Access is by way of a single user ID and password. Firms must request access to IARD/Web CRD by completing and submitting the New Organization SAA Form and completing the entitlement process as outlined in the applicable Entitlement Information Packet:The Entitlement Program requires that each firm designate a Super Account Administrator (SAA), who will have the authority to create, modify and delete account administrator and user accounts for FINRA-administered applications. IA firms seeking SEC-registration, state-registration or filing as an exempt reporting adviser must

Once a request is received to establish a Web Services Account, the FINRA Entitlement Group will confirm that the identity of the requester (Authorized Signatory), matches the contact information filed on your firm’s most recently filed Form ADV.
FINRA will then generate an Entitlement Form. This form will include pre-populated information such as Firm CRD number, name, etc., as well as a unique identifier assigned by FINRA.
FINRA will send the Entitlement Form to the Authorized Signatory’s email address, facsimile number or physical location as listed on your firm’s latest Form ADV.
Upon receipt of a completed Entitlement Form, FINRA will create a Web Services Account for your firm. It may take up to four business days to create an account.