Use of Data Collected from Form PF

compliance and form pf

Many private funds struggled with getting Form PF filed. Many in fund compliance were dubious that the Securities and Exchange Commission would be able to do anything meaningful with the massive amount of data pushed through the form. Regardless, Section 404 of Dodd-Frank required the SEC to gather the data so the Financial Stability Oversight Council could assess systemic risk.

Section 404 also required an annual report on how the SEC has used the data collected in Form PF. The first report came out a short time ago.

In total, there are big numbers:

Types of Private Funds Advised by all Filers

  • 6,683 Hedge Funds ($4.061 trillion cumulative RAUM)
  • 5,928 Private Equity Funds ($1.603 trillion cumulative RAUM)
  • 2,922 Other Private Fund Type ($698 billion cumulative RAUM)
  • 1,121 Real Estate Funds ($299 billion cumulative RAUM)
  • 966 Securitized Asset Funds ($338 billion cumulative RAUM)
  • 329 Venture Capital Funds ($23billion cumulative RAUM)
  • 66 Liquidity Funds ($258 billion cumulative RAUM)

For a total of $7.280 trillion in Private Fund Regulatory Assets Under Management Reported by all Filers

The report goes on to imply that the SEC is still figuring out what to do with the data after it passes on the information to FSOC.

The mysterious Division of Economic and Risk Analysis is plugging some of the information into its black box of analytic tools.

More importantly for fund managers, the Office of Compliance Inspections and Examinations is using the information for pre-examination and research. Once selected for an exam, a fund manager should assume that the examiners have a copy of Form PF. OCIE is also working with a system to use Form PF to identify red flags that could trigger exams.

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