SEC Open Meeting, October 26, 2011

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Dodd-Frank Timeline, Investment Adviser Reporting, Joint SEC-CFTC Rulemaking
Final Rule Issue Effective Date Compliance Date
November 16, 2011 March 31 2012 June 15, 2012*

The U.S. Securities and Exchange Commission (SEC) held a public meeting on October 26, 2011 focused on reporting of information to the Financial Stability Oversight Council (FSOC) by advisers to hedge funds and other private funds, as a way to monitor risk. The final rule implements Sections 404 and 406 under the Dodd-Frank Wall Street Reform and Consumer Protection Act.

The final rule "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)."[1]

The rules divide investment advisers into two groups, large advisers and smaller advisers, and will go into effect using a two-stage phase-in period for compliance.

Archived webcast:

Final Rules

Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF

Read final rule.png


Commissioner Troy A. Paredes, whose statements include:

  • "In short, as the release explains, advisers will be allowed more time to file Form PF; the threshold that delineates a large private equity fund adviser has doubled; large private equity fund advisers will have to file less frequently; advisers will generally have to report less information; fewer advisers will have to file the Form; and advisers will have more flexibility to use their existing methodologies and recordkeeping practices to comply with the rule."
  • Support for the final rule.[2]

Chairman Mary L. Schapiro, whose statements include:

  • An explanation of the origins of Form PF.
  • An explanation of “tiered” reporting, reporting by large equity managers, the timing and frequency of reporting, and confidentiality under Form PF.[3]

Commissioner Luis A. Aguilar, whose statements include:

  • "To monitor systemic risk is a herculean task. To do it blindly is to invite failure. At least today, one step has been taken to collect and provide FSOC with reliable, necessary information to further its own mission and foster stability within the financial system."[4]


  1. SEC Approves Confidential Private Fund Risk Reporting. SEC. Retrieved on October 26, 2011.
  2. Speech by SEC Commissioner: Statement at Open Meeting to Adopt Form PF by Commissioner Troy A. Paredes. SEC. Retrieved on October 26, 2011.
  3. Speech by SEC Chairman: Opening Statement at SEC Open Meeting: Private Fund Systemic Risk Reporting by Chairman Mary Schapiro. SEC. Retrieved on October 26, 2011.
  4. Speech by SEC Commissioner: “Obtaining Reliable Information Regarding Private Fund Advisers” by Commissioner Luis A. Aguilar. SEC. Retrieved on October 26, 2011.

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