Proposed Amendments to Form PF Require More PE Sponsors to File and One‑Business‑Day Reporting Criteria (Part One of Two)

The SEC voted, over spirited dissent from Commissioner Hester M. Peirce, to propose amendments to Form PF (Proposal). First, the Proposal would require large hedge fund advisers and all PE advisers to file a report within one business day after certain stress events occur that could adversely impact investors or the broader financial markets. Second, it would require additional reporting by large PE fund advisers in Section 4 of Form PF. Finally, the Proposal would lower the reporting threshold to capture PE firms with at least $1.5 billion in assets under management. The comment period for the Proposal expires March 21, 2022. This first article in a two-part series details the SEC’s reasoning behind the Proposal, the proposed changes that will impact PE sponsors and the topics under consideration during the comment period. The second article will break down the individual SEC Commissioners’ remarks on the Proposal; concerns in the PE industry about the scope and practical impact of the Proposal; and the likelihood of it being enacted. See “The SEC’s 2021 Reg Flex Agendas: Key Items for Private Funds and the Rulemaking Process (Part Two of Two)” (Sep. 28, 2021); and “Former OCIE Official Discusses SEC’s Latest Reg Flex Agendas” (Dec. 8, 2020).

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