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The IAA Statement on SEC Form PF Amendments

May 3, 2023

IAA VP of Communications & Marketing Janay Rickwalder.

The IAA supports the SEC’s efforts to monitor and assess for systemic risk as well as to bolster investor protection. However, we opposed aspects of the Form PF proposal because the proposed changes were overbroad, requesting information that will not meaningfully assist in systemic risk monitoring. We made specific recommendations on many items, including to modify, remove, or change the timeframe for reporting various items.

We appreciate that the SEC appears to have responded to many of the IAA’s concerns. However, while we are continuing to review the release, we have preliminarily identified several remaining troubling issues, including:

  • Despite calls to do so, the SEC did not adopt today’s amendments together with a second set of proposed amendments included in the joint SEC/CFTC August 2022 proposal that would restructure much of the way Form PF is filed. The IAA strongly believes the SEC should not require advisers to make the technological, operational, and systems changes to their Form PF filings that will be required under the new amendments without first analyzing and considering how these changes will be impacted by the changes to the same Form proposed in August.
  • The six-month compliance date for the new current reporting following a trigger event is unreasonably and unrealistically short. It does not appreciate the challenges advisers will face to operationalize and implement these changes across their systems to ensure that the reportable events are identified, captured, and relayed within the required timeframe. The IAA had asked for a more reasonable 18 months for advisers to make these changes.
  • The IAA still has significant concerns about the number and types of reportable events, as well as the deadline and frequency of filings required by the final amendments, which will all be extremely challenging for our members.

The IAA appreciates that the SEC made the following important changes from the proposal, consistent with the IAA’s requests:

  • Extended the filing deadline for large hedge fund advisers to file after a trigger event from one business day to 72 hours, even though the IAA had requested five business days;
  • Extended the one-business-day reporting for private equity fund advisers to a quarterly report;
  • Did not adopt a requirement that a hedge fund adviser report a significant decline in holdings of unencumbered cash;
  • Did not decrease the threshold for large private equity adviser from $2 billion to $1.5 billion in private equity fund AUM; and
  • Did not adopt the term “digital assets” as a new term to the Form PF Glossary of Terms.

Given the sensitive nature of Form PF data, the IAA also continues to urge the SEC to ensure robust controls around maintaining confidentiality of Form PF data.

SEC Fact Sheet

The full comment letter is available on the IAA website.

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