SEC Form PF Reporting Changes Effective Dec. 11, 2023, And June 11, 2024

The U.S. Securities and Exchange Commission ("Commission") adopted amendments to Form PF ("Adopted Amendments"), the confidential reporting form for certain investment advisers registered with the Commission. Many advisers to large private funds will need to update their policies and systems, and create new systems, to satisfy the new obligations, which will include identifying, reviewing and analyzing more and different types of information and, in some cases, to report within 72 hours of a triggering event.

In addition to introducing major changes to how respondents must complete Form PF, the Commission and its Staff made it clear that it will use Form PF for general oversight of investment advisers, including as part of the Commission's examination program. The Commission is expected to use certain reporting events as examination scoping and may be more likely to initiate an examination of an adviser who has experienced certain reporting events, such as an