Does my RIA firm need to file a Form PF?

Learn what about an RIA firm's criteria requires filing a Form PF.

Which RIA firms need to file a Form PF?

According to the SEC's Form PF general instructions, an RIA firm is required to compile and file a Form PF when all three of the following characteristics are met:

  1. The firm is registered or required to federally register with the SEC as investment adviser AND
  2. the firm manages one or more private funds AND
  3. the firm (and its related persons) collectively manage at least $150 million in private fund assets under management ("AUM") as of the last day of the most recently completed fiscal year.

Related: Click here to access the most recent version of the Form PF from the SEC website

Which sections does a private fund need to complete on the Form PF?

ll Form PF filers, regardless of private fund AUM, must complete Section 1a and Section 1b. All private fund advisers required to file a Form PF that advise one or more hedge funds, regardless of total hedge fund AUM, are required to complete section 1c. Some larger private fund advisers may also be required to complete additional section(s) of the Form PF:

  • "Large hedge fund advisers" designated as firms and related persons that collectively manage at least $1.5 billion in hedge fund AUM are required to complete Section 2.
  • "Large liquidity fund advisers" designated as firms and related persons that collectively manage at least $1.0 billion in liquidity fund AUM are required to complete Section 3 for each liquidity fund.
  • "Large private equity advisers" which are designated as firms and related persons that collectively manage at least $2.0 billion in private equity fund AUM are required to complete Section 4 for each private equity fund.

Where do I file the Form PF (and how much does it cost)? 

All Form PF filings are submitted via the private fund reporting depository ("PFRD") which is part of the IARD online filing system. The IARD system assesses a $150 fee on all Form PF filings.

Does a state-registered or exempt reporting adviser ("ERA") need to file a Form PF?

Given the criteria above, SEC-registered RIA firms with less than $150 million in private fund AUM, exempt reporting advisers, and state-registered RIA firms are generally not required to file a Form PF. However, it's important to note that those firms are still generally required to file a Form ADV, which will disclose general information about the private funds they manage.

When must an RIA firm managing a private fund file a Form PF?

While large hedge fund advisers, large private equity advisers, and large liquidity fund advisers are required to submit quarterly Form PF filings, all other private fund advisers are generally required to file an annual Form PF update within 120 calendar days after the end of the fund's fiscal year. 

RIA firms filing a Form PF for the first time will disclose it is the firm's initial Form PF filing. Going forward, the firm will then disclose that it is submitting a quarterly or annual update.