The SEC has updated its frequently asked questions on Form PF.  The updates include:

  • General filing information: Questions A.7 through A.9 on rounding, amendments to Form ADV on new private funds, and liquidation of funds.
  • Question 14.2 on assets and liabilities in the cost-based column that would be presented in a fund’s financial statements using a measurement attribute other than fair value.
  • Question 24.3 on use of gross notional values for trading data.
  • Question 35.2 indicating cash and cash equivalents are not a “position” for purposes of reporting open positions in Questions 35 and 57.
  • Question 46 addressing whether guidance provided by the staff regarding borrowings for Question 12 and 43 also apply to how borrowings should be interpreted for Questions 46 and 47.
  • Question 47, which refers to Question 46.