Preparing For The Amended Form PF

In May 2023, the SEC adopted amendments to Form PF, which change certain existing questions and create new events-based reporting requirements. With the compliance date for new events-based reporting set for December 11, 2023, private fund advisers should be actively reviewing their policies and procedures to ensure they are ready to comply with the new requirements during periods of significant market volatility. Private fund advisers should also ensure that they are on target to respond to changes to existing sections of Form PF that have a later compliance date of June 11, 2024.

New Questions for Large Private Equity Fund Advisers (Section 4)

The amendments to Form PF¹ add or modify several reporting items in Section 4, including questions relating to (i) fund strategies; (ii) general partner and certain limited partner clawbacks; (iii) fund-level borrowings; (iv) events of default; (v) bridge financing to controlled portfolio companies; and (vi) reporting on