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Alternative Market Briefing

Form PF highlights the need for consensus, planning at funds

Tuesday, April 10, 2012

amb
Vernon Barback
Bailey McCann, Opalesque New York:

As part of the slate of new regulations imposed on hedge funds by the Dodd-Frank Act, funds will now be required to submit a Form PF to the Securities and Exchange Commission (SEC). The form will be used by the SEC and the Financial Stability Oversight Council (FSOC) to measure systemic risk and keep tabs on funds overall. The first deadline for Form PF highlighted the need for consensus across all aspects of a fund, and those tasked with compiling the form for funds are going out of their way to emphasize how much time and data is required to file the form correctly before the next round is due.

While the form itself numbers in the tens of pages, large funds with multiple strategies or a significant asset base can expect to turn in a finished filing that is hundreds of pages long. Estimates for the amount of time involved in completing a single form range from 300-2000 hours depending on how a given filer is set up.

For administrators or accountants, much of the data needed for the form is readily available however, it will need to be compiled from a broad range of sources. Additionally, many of the questions and much of the guidance from regulators are somewhat vague by design in order to give funds room for judgement in terms of how best to present the required information about their business. Taken together, these factors have presented challenges for funds and their administrative staff as they try to provide the necessa......................

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