Can the alternatives industry live with Form PF?
In the wake of Dodd Frank, the new registration requirement for hedge funds and private equity funds generated a lot of media attention. For people in the industry, there was just as much worry about the proposed Form PF, which seemed so onerous to many as it required a slew of unprecedented disclosures to the Financial Stability Oversight Council. The idea was to give the government more information with which it could better assess systemic risks. The alternatives industry went to work from a lobbying perspective, and can claim a big victory, as the new Form PF requirements are now much more to the industry's liking. Bloomberg reports that no less than Blackrock, among the most influential asset managers, has given the rules an enthusiastic thumbs-up. The industry was pleased that the reporting requirements by the SEC and the CFTC have been harmonized, and that the frequency with which private equity firms have to report has been reduced; they will file annually instead of quarterly. For more of the specifics, see this write-up from Fried Frank. Still, compliance with Form PF will not necessarily be a cinch. Like the registration requirement, this will be a major undertaking, especially in the initial years. We'll likely have more on this in the near future. Most private fund advisors 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. Some larger advisors will have to file earlier.
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