Posted by Marc E. Elovitz, Schulte, Roth & Zabel LLP, on Friday, February 25, 2022
Editor’s Note: Marc E. Elovitz is partner at Schulte, Roth & Zabel LLP. This post is based on his SRZ memorandum.
The Securities and Exchange Commission is proposing significant increases to reporting by hedge and PE fund advisers on Form PF. More details and analysis to come, but the key points identified by the SEC in voting to make the proposal are as follows:
Current Reporting of Certain Events by Large Hedge Fund Advisers. Large hedge fund advisers would be required to file current reports within one business day of the occurrence of one or more reporting events with respect to their qualifying hedge funds:
- 20% or more losses
- Significant margin and counterparty default events
- Material changes in prime brokerage relationships
- Changes in unencumbered cash, operations events and events associated with withdrawals and redemptions
Current Reporting of Certain Events by Private Equity Fund Advisers. Private equity fund advisers would be required to file current reports within one business day of the occurrence of one or more reporting events pertaining to:
