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The amended version of Form PF defines a trading vehicle as a separate legal entity that is wholly or partially owned by one or more reporting funds that holds assets, incurs leverage, or conducts trading or other activities as a part of the reporting funds investment activities, but does not operate a business.
Form PF is a regulatory filing that certain private fund advisers must file with the U.S. Securities and Exchange Commission (SEC). The Treasurys Financial Stability Oversight Council (FSOC) uses detailed information from Form PF to gain visibility into the behaviors and risk profiles of private funds.
Advisers that have at least $150 million in private fund assets under management but that do not exceed a large adviser threshold must file Form PF only once a year. These small private fund advisers are required to fill out basic information on the private funds they advise.
Exempt reporting advisers (ERAs), a type of investment adviser that is not required to register with the SEC or a state securities regulator, do not have to file Form PF.
The new compliance date for Form PF is June 12, absent further delays. After the compliance date, the first filings required on the new form will be: For Large Hedge Fund Advisers (Quarterly Filers): the filing covering Q2 2025, due on August 29, 2025.
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Smaller private fund advisers file Form PF on an annual basis, while Large Hedge Fund Advisers file quarterly within 60 days after the advisers fiscal quarter-end. Large Hedge Fund Advisers must report more information about Qualifying Hedge Funds than other hedge funds they may also manage.
Filing Form PF requires basic information about the adviser, any related persons, assets under management, etc. It also asks for information about each private fund including asset values, borrowings, investor classifications, performance, strategy, counterparties and trading style.

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