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SEC Proposed Form PF Changes: How to Prepare for 2023

Over the past year, the SEC has proposed changes to Form PF, the confidential reporting form for advisors to private funds. Managers should act now to achieve basic testing on time. You will need time to test your preparations for the switch and requisite systems, as well as be able to run at least two parallel periods in order to provide a base of reference to compare with the first live filing version. Whether a manager chooses an outsourced or self-built solution, the testing period is closing.

Some examples of the changes and how they will impact managers include more exhaustive exposure reporting including additional calculations determined by thresholds, the inclusion of capital activity, the need for new data points, changes to fund aggregation and significant changes to counterparty exposure and borrowings.

Wholesale changes to the form include how large hedge fund advisors report, with seven new event-driven requirements for HF managers with one-day disclosure deadlines, and a lowered threshold for large private equity advisors from US$2 billion to US$1.5 billion. There are also additional questions added to Section 4 requiring further disclosure of investment strategies, restructuring or recapitalization, various aspects of intra-fund ownership, and multiple aspects of borrowing and controlled portfolio companies.

In our "AIMA Fund Manager Briefing" webinar, we outline a to-do list of what managers can do to prepare for these changes in 2023.

  • Arrange your alerts for SEC releases/AIMA messages regarding Form PF.
  • Decide whether to manage the project in-house or outsourced.
    • If using an outsourced or specialist software solution, check with the provider that preparations and contingency planning are underway and whether your action is required in advance.
    • If produced in-house, ensure the relevant teams are aware of all details and changes.

SS&C GlobeOp provides an end-to-end Form PF solution that includes the creation of a validated regulatory book of records, an explanation of the data required, mapping of data, aggregation, comparison of the methodology used by peers, production of reports for review and data analytics. To learn more about how to prepare for the coming Form PF changes, download our brochure or  view the full "AIMA Fund Manager Briefing" webinar.

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