SEC and CFTC Jointly Adopt Form PF


The Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC”) recently adopted new rules (the “Rules”) under the Investment Advisers Act of 1940 (the “Advisers Act”), and the Commodity Exchange Act (the “CEA”) that will require registered investment advisers with at least $150 million in private fund assets under management to file Form PF with the SEC. Form PF is designed to implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), and the information gathered by the form is primarily intended for use by the Financial Stability Oversight Council (the “FSOC”) in assessing systemic risks posed to the U.S. financial system. While the information reported on Form PF generally will remain confidential, the SEC and the CFTC will be permitted to use Form PF information in examinations, investigations and enforcement actions.

To read the full alert, including details on the scope of the rules and an overview of reporting requirements, click on the PDF linked below.


For additional information regarding the Rules or Form PF, please contact one of the attorneys listed below:

Taylor H. Wilson


Evan K. Hall

Kit Addleman

Richard M. Fijolek


Vicki L. Martin-Odette


David Siegal



Rick A. Werner

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