The Securities and Exchange Commission (the “SEC”) staff recently released an updated set of questions and answers in its “Frequently Asked Questions” relating to Form, and several of these clarifications may be useful to private fund advisers.
Among the updates, the SEC clarified that related persons do not need to be identified in Question 1(b) of Form PF because Form PF does not require, but instead permits, related persons to report on a single Form PF as a matter of convenience. Generally, Question 1(b) of Form PF requires certain information about related persons of the Form PF filer, including such related person’s CRD or SEC file number. The SEC further clarified that it is necessary to identify a related person in Question 1(b) only if a filer is reporting information on Form PF with respect to such related person.
The SEC also explained that if a master-feeder arrangement is reported in the aggregate for purposes of Section 7.B.1 of Form ADV and the adviser wishes to report private funds in the master-feeder arrangement separately on Form PF, then the adviser must first file an “other-than-annual amendment” to Form ADV to reflect such changes. This will ensure the reporting and treatment of master-feeder structures are consistent between Form ADV and Form PF.
The SEC’s Frequently Asked Questions relating to Form PF is available here.