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US Asset Management and Investment Funds Alert authored by Pablo J. Man, Ruth E. Delaney, Gustavo De La Cruz Reynozo, lawyers at K&L Gates.

Introduction and summary

On 3 May 2023, the Securities and Exchange Commission (SEC) approved amendments to Form PF (the Amendments), the confidential reporting form required to be filed by certain SEC-registered private fund advisers. The Amendments relate to changes initially proposed in January 2022. Additional changes to Form PF, jointly proposed by the SEC and the Commodity Futures Trading Commission (CFTC), in August 2022 remain under consideration.

The Amendments significantly expand the scope of Form PF's existing reporting obligations. As adopted, the Amendments to Form PF require:

Current reporting requirements for large hedge fund advisers

In addition to their existing quarterly filing obligations, advisers with at least US$1.5 billion in assets under management attributable to hedge funds must report certain events with respect to qualifying hedge funds - such as extraordinary investment losses, significant margin and default events, and large withdrawal and redemption requests - to the SEC as soon as practicable, but no later than 72 hours, after they occur.

Quarterly......................

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