SEC adopts final Form PF: certain implications for hedge fund and private equity fund advisers

On October 31, 2011, the U.S. Securities and Exchange Commission (the “SEC”) and the U.S. Commodity Futures Trading Commission (the “CFTC”) adopted final rules1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and the Commodity Exchange Act,2 respectively, to implement Sections 404 and 406 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).