IM Issues New Guidance on Form PF

The SEC’s Division of Investment Management (IM) updated the Form PF FAQ available on the SEC website. The updates are intended to provide guidance for firms filing their annual or quarterly updates in the coming months. IA Release No. 3879 (note the release number stated in the IM Update is incorrect) on money market fund reforms facilitated the need for certain revisions due to the new requirements for unregistered liquidity funds. Listed below is a summary of the major changes identified by the corresponding FAQ Question:

  • Question 20: When gross assets are greater than net assets, the total % of the NAV number for each category should total more than 100%.
  • Question 32: A fund that only holds cash and cash equivalents should report that 100% of its assets are liquid.
  • Question 35: Cash and cash equivalents should not be included as a “position.”
  • Question 47: The affiliated creditor group is selected in the drop down box for this item; however, Question 4 is where the specific affiliated creditor is identified by name.
  • Question 49: Only include those discretionary restrictions that are above and beyond the explicit restrictions as disclosed in the offering documents.
  • Question 50: Include side-letter variances or other investor specific terms when determining the % of NAV locked up for different time periods.
  • Question 63: Derivative holdings are to be reported under the “other” security category.

Registered investment advisers to private funds should review their previous responses to the above Questions in consideration of the revised FAQ and amend their responses for the next filing update, as needed.

View the SEC IM Information Update, “Updates to Form PF Frequently Asked Questions,” January 2017