Overarching Takeaways From the Final Form PF Amendments and Suggestions for How PE Sponsors Can Prepare to Comply (Part Two of Two)

The SEC recently adopted final amendments to Form PF (Final Rules) that impose additional reporting requirements on private fund advisers. Although the Final Rules may be more balanced and less onerous than other recent SEC rulemakings and proposals, certain commissioners and private funds experts remain concerned about the SEC’s alarmism around adviser-led secondary transactions and its strong emphasis on investor protection questions in Form PF. This second article in a two-part series discusses the response of SEC commissioners and the private funds industry to the Final Rules and their impact on closed-end fund managers; highlights key takeaways; and suggests next steps for fund managers to take to achieve compliance. The first article summarized the provisions of the Final Rules affecting PE fund advisers and key differences from the proposed amendments to Form PF. For commentary from SEC commissioners on other recent rulemaking, see our two-part series: “Peirce and Roisman Argue Against Prescriptive ESG Disclosures” (Aug. 24, 2021); and “Gensler and Lee Advocate Further SEC Oversight of ESG Efforts” (Aug. 31, 2021).

To read the full article

Continue reading your article with a PELR subscription.