On October 26th, the SEC voted unanimously to adopt a new rule requiring certain advisers to hedge funds and other private funds to report information for use by the Financial Stability Oversight Council ("FSOC") in monitoring risks to the U.S. financial system. The rule, which implements Sections 404 and 406 of the Dodd-Frank Act, requires SEC-registered investment advisers with at least $150 million in private fund assets under management to periodically file a new reporting form (Form PF). The CFTC is expected to vote on jointly adopting these reporting requirements within the next week. There will be a two-stage phase-in period for compliance with Form PF filing requirements. Most private fund advisers will be required to begin filing Form PF following the end of their first fiscal year or fiscal quarter, as applicable, to end on or after December 15, 2012. However, certain advisers, those with at least $5 billion in assets under management attributable to hedge funds, private funds, liquidity funds, or registered money market funds, must begin filing Form PF following the end of their first fiscal year or fiscal quarter, as applicable, to end on or after June 15, 2012. SEC Press Release. The Washington Post reported that comments submitted to the SEC on the proposed rule indicate that opponents of the rule may be preparing to challenge them. Groundwork. However, Commissioner Luis A. Aguilar noted that when compared to the proposed rule, the adopted rule applies to fewer firms, requires less frequent filing, and gives firms more time to file. Aguilar Open Meeting Remarks. Chairman Mary Schapiro commented that the data collection form will require substantially less information from advisers managing large private equity funds than that required from advisers to large hedge fund and liquidity funds. Schapiro Open Meeting Remarks.