Form PF: what it asks and where the data lives
Who files, when, and why the filing is easier when the fund's books already hold the answers.
Who has to file Form PF?
SEC-registered investment advisers that advise one or more private funds and have at least $150 million in private fund assets under management file Form PF. Most private equity advisers file annually within 120 days of fiscal year-end; large hedge fund advisers file quarterly, and large private equity advisers complete additional sections.
What it asks
Fund-level information such as gross and net assets, borrowings and financing, investor concentration and types, performance, and — for larger advisers — additional detail on portfolio companies, leverage and strategy. Requirements have been amended several times; check the current form instructions with counsel.
Where the data should come from
Almost every figure the form asks for is a fund-level fact that already exists in well-kept books: NAV, commitments, borrowings under facilities, investor composition by type and domicile, performance. When the filing is built from the ledger, it is repeatable and consistent with LP reporting.
Process tips
Fix definitions once (what counts as borrowings, how investors are categorised), document them, and generate the same extracts every period. Reconcile Form PF figures to the audited financials.
Questions
Does FUN/D file Form PF?
No. It holds the data the filing uses.
Is this legal advice?
No. Confirm your obligations with counsel.
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