Form PF

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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*
Dodd-Frank Timeline, CPO/CTA Registration, CFTC
Final Rule Issue Effective Date Compliance Date
February 9, 2012 July 2, 2012 by December 2012*

The U.S. Securities and Exchange Commission (SEC) finalized its rules regarding private fund systemic risk reporting (Form PF) at its October 26, 2011 open meeting. The Commodity Futures Trading Commission (CFTC) is proposing rules to specify the reporting requirements applicable to advisers to private funds that are registered with the SEC as investment advisers and with the CFTC as commodity pool operators (CPOs) or commodity trading advisors (CTAs). This is a joint rulemaking with the SEC.

See Private Fund Systemic Risk Reporting Regulation for more information.

Final Rules from SEC Open Meeting, October 26, 2011

  • Implements Sections 404 and 406 under the Dodd-Frank Wall Street Reform and Consumer Protection 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)."[1]
  • Divide investment advisers into two groups, large advisers and smaller advisers.
  • Uses a two-stage phase-in period for compliance.


The proposed CFTC rule would require CPOs and CTAs registered with both the CFTC and SEC to satisfy certain proposed CFTC filing requirements by filing Form PF with the SEC. Reports must include a description of certain information about private funds for each private fund advised by the adviser, such as:

  • the amount of assets under management,
  • use of leverage,
  • counterparty credit risk exposure,
  • trading and investment positions,
  • the proposed registration, reporting, and compliance requirements.

The final rule release, the rule proposal and a copy of Form PF can be found below.


  1. SEC Approves Confidential Private Fund Risk Reporting. SEC. Retrieved on October 26, 2011.

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