Form PF Filing System Active
As we have discussed in previous posts, many hedge fund managers are going to be required to complete Form PF on either a quarterly or annual basis. The filing will be made through a new filing system administered by FINRA called the PFRD (Private Fund Reporting Depository). Many funds will have outside groups who will be accessing the system on their behalf. Smaller funds may be able to complete the form themselves.
If you have questions on the form or accessing the PFRD, please contact us.
The PFRD announcement from FINRA is reprinted below.
To: Super Account Administrators of Investment Advisers
From: FINRA Entitlement Group
Date: June 4, 2012
Re: New Electronic Private Fund Reporting Depository (PFRD) System Entitlement
The new electronic Private Fund Reporting Depository (PFRD) System facilitates investment adviser reporting of private fund information via Form PF. Beginning today, if you are an investment adviser that is required to report private fund information, you have the ability to entitle yourself as a user to this new application; update existing accounts; and/or create new accounts with this new application. Your current user ID and password remain valid. To determine if you are required to file Form PF, refer to the criteria below.
Complete and file Form PF if:
• You are registered or 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.
For more information on the PFRD System, refer to the information on the IARD web page: http://www.iard.com/pfrd/default.asp.
For questions concerning:
• Form PF filing requirements or policy issues, contact the SEC at (202) 551-6999 or IARDLIVE@sec.gov.
• Technical questions regarding the PFRD System, contact the FINRA Gateway Call Center at (240) 386-4848.
• FINRA Entitlement, contact the FINRA Entitlement Group at (240) 386-4185.
Bart Mallon is a partner with Cole-Frieman Mallon & Hunt LLP, an investment management law firm. Bart can be reached directly at 415-868-5345.