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ARTICLE · 02 NOVEMBER 2011

The SEC Approves Final Version Of Form PF

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The Securities and Exchange Commission (the "SEC") held an open meeting on Wednesday, October 26, 2011, regarding the adoption of a rule requiring certain registered investment advisers to hedge funds and other private funds to report information on Form PF for use by the Financial Stability Oversight Council ("FSOC") in monitoring systemic risk to the U.S. financial system.

United StatesFinance and Banking
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The Securities and Exchange Commission (the "SEC") held an open meeting on Wednesday, October 26, 2011, regarding the adoption of a rule requiring certain registered investment advisers to hedge funds and other private funds to report information on Form PF for use by the Financial Stability Oversight Council ("FSOC") in monitoring systemic risk to the U.S. financial system. The new rule, Rule 204(b)-1 under the Investment Advisers Act of 1940, would implement sections 404 and 406 of the Dodd-Frank Act and was initially proposed, along with the Form PF, on January 26, 2011. See 76 Fed. Reg. 8068 (Feb. 11, 2011).

At the meeting on Wednesday, the SEC unanimously approved the final version of Form PF and highlighted the manner in which the final form differs from the form as proposed. This memorandum summarizes the key Form PF changes that were highlighted at the meeting. The SEC has not yet published the full text of the adopting release or the final version of the

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