The SEC staff recently released an updated set of questions and answers in its “Frequently Asked Questions” relating to Form PF. Of particular note, the SEC added a new question, in which it indicated that when filing other-than-annual amendments to Form ADV for the sole purpose of generating a private fund identification number for a new private fund for Form PF, an adviser is only required to update Section 7.B.1 (with respect to the new private fund). However, it is advised that if making such other-than-annual amendment, an adviser should consult the Instructions to Form ADV to determine whether it must update any additional information.
Additionally, with respect to reporting private funds that are liquidated during a reporting period on Form PF, the SEC clarified that such liquidated funds must be included in Form PF if they were in existence during the reporting period. To clarify the current liquidated status of a fund, the SEC recommended including such information in Question 4 to Form PF (which requests a filer include any assumptions or other relevant information with respect to its filing).
Finally, the SEC provided guidance with respect to specific Form PF questions, including clarification on how cost-based calculations should be made and how borrowings should be interpreted for purposes of certain questions.
Form PF filers should review the updated “Frequently Asked Questions” to ensure they are appropriately answering and providing all information required by Form PF.