What is PFRD?
The Private Fund Reporting Depository (PFRD) is a new electronic filing system that facilitates investment adviser reporting of private fund information via Form PF. The U.S. Securities and Exchange Commission (SEC) website provides detailed information regarding the new reporting requirements for certain advisers to private funds. Form PF may be filed electronically through a Web form that is completed online or by XML submission.
FINRA is the developer and operator of the PFRD system, which has been developed according to the requirements of its sponsor, the SEC.
Who Should File Form PF?
Most investment advisers (IAs) will not be required to file Form PF or use the PFRD system. The following is an excerpt from the Form PF describing, at a high level, who is required to file:
- Complete and file Form PF if:
- You are registered or required to register with the SEC as an investment adviser, or you are registered or required to register with the Commodity Futures Trading Commission (CFTC) as a commodity pool operator or commodity trading advisor and you are also registered or required to register with the SEC as an investment adviser; and
- You manage one or more private funds; and
- You and your related persons, collectively, had at least $150 million in private fund assets under management as of the last day of your most recently completed fiscal year.
If you do not meet the foregoing criteria, you do not need to file Form PF or use the PFRD system.
On June 4, 2012 Super Account Administrators for all SEC-registered investment advisers were given entitlement to grant "Use" privileges to the PFRD system.
When must a Current Report be filed?
The SEC Rule Amendments to require filing of Current Reports became effective Dec. 11, 2023. From the Form PF Instructions: Large hedge fund advisers must file a current report in Section 5 and advisers to private equity funds must file a current report in Section 6, upon certain reporting events. See Section 5 and Section 6, respectively, for filing deadlines.
Are there fees to file the Form PF?
Yes. A $150 fee will be assessed for the Initial Form PF and each Update filing (i.e., the first filing for each new reporting period). This means that quarterly filers will be charged $150 four times each year and annual filers will be assessed $150 once each year. There will be no fees assessed for Amendment filings (i.e., changes made to a previously filed Form PF for a particular reporting period).
Questions?
Questions regarding Form PF filing requirements or policy issues should be directed to the SEC at (202) 551-6999 or [email protected].
Technical questions regarding the PFRD system should be directed to FINRA at (240) 386-4848 or [email protected].