Adapting to the Latest Form PF Amendments: What Your Firm Needs to Know

The Securities and Exchange Commission (SEC) recently rolled out the third set of amendments to Form PF within the last 12 months. These amendments, arguably the most substantial to date, will significantly impact all filers. Large hedge funds are expected to feel the greatest strain.

What do these changes mean for your compliance team, risk controls, and overall operations? How can you plan to efficiently manage the increased volumes of detailed data Form PF will soon require?

In this blog, we’ll answer both of these questions by breaking down the key amendments, the challenges they present, and how your firm can meet compliance deadlines while navigating the continuous evolution of Form PF.

Key Changes in Form PF Reporting

The latest amendments to Form PF—particularly those affecting Sections 1 and 2—redefine how feeder funds, parallel funds, and fund-of-funds are treated, broadening the scope of entities required to report. Form PF filers must now provide deeper insights into investments, including trading vehicles and funds in which you invest. Additionally, reporting on investment and counterparty exposures has been revamped to include much more granular data.

In addition to these “big headline” changes, there are several smaller adjustments to Sections 1 and 2 that will require firms to revisit current Form PF processes to ensure full compliance.

The compliance deadline for all these amendments is March 12, 2025, so large hedge fund and liquidity fund advisors in particular have a tight window in which to ensure compliance with the updated reporting requirements for Q1 2025 filings. Other filers will need to implement the changes for year-end 2025 reports.

Challenges Ahead for Investment Managers

The new Form PF amendments present several challenges for investment managers and fund advisors, including:

1. More granular information about funds: Feeder funds, parallel funds, and fund-of-funds are now included within the reporting scope, increasing the workload for compliance teams.
2. Detailed data collection: Firms will need to gather intricate details about the underlying investments of internal non-reportable funds and trading vehicles. This deeper dive into data could be time-consuming, especially for larger firms managing numerous investments.
3. Overhauled investment and counterparty exposure reporting: The new format for reporting investment and counterparty exposures will require firms to provide more detailed information than before for example the lending/posted collateral and Borrowing/CollateralReceived at each counterparty level, adding complexity and time to the reporting process.
4. Comprehensive review of Form PF processes: Smaller adjustments across Sections 1 and 2 mean that a holistic review of your current Form PF procedures will be necessary to avoid costly mistakes or lapses in compliance.
5. Tight deadlines: Given the March 2025 compliance date, firms have a limited time to assess, optimize, and overhaul Form PF processes—which will likely increase the pressure on compliance teams that are already managing significant workloads.

Tackling Data Complexity and Tight Deadlines

The SEC’s strict compliance window leaves large hedge fund advisors and liquidity fund advisors with little time to revamp reporting methodologies ahead of Q1 2025.

The intensity of the new reporting demands will require a more granular level of data collection and analysis than ever before. From feeder funds to counterparty exposures, the new requirements place a premium on efficiency and accuracy. The scale of these changes requires a technology-driven approach to streamline data gathering and regulatory reporting. In other words, investment managers must have robust data management systems capable of quickly integrating, validating, and analyzing vast quantities of information.

How the IVP Regulatory Reporting Solution Can Help

To help asset manager take on these new challenges, the IVP Regulatory Reporting Solution offers a comprehensive, automated platform that complies with the latest Form PF amendments with ease. Here’s how it supports your reporting needs:

Automated data collection: IVP’s solution seamlessly integrates with existing data sources to automate the collection of all the details required under the new Form PF guidelines.

Data validation and accuracy: With built-in validation checks, the solution ensures that data is accurate and compliant before submission, reducing the risk of errors and regulatory penalties.

Flexible reporting framework: The solution adapts to evolving regulatory requirements, including feeder fund and counterparty exposure reporting, providing customizable reports that align with the SEC’s latest Form PF amendments.

Accelerated filing: By automating much of the data preparation and validation process, IVP’s solution accelerates your filings, helping you meet tight deadlines without sacrificing accuracy.

One-click submission: The solution supports machine-to-machine Form PF XML submission directly from the main interface, so compliance teams can avoid the hassle of manual downloads and redundant XML testing.

Take a Strategic Approach to Compliance

To navigate these new amendments effectively, investment managers need to take a strategic approach to Form PF reporting. That means firms will need to:

1. Start early: Begin planning and implementing changes to Form PF processes immediately. This will reduce the risk of a last-minute rush that compound your compliance issues.
2. Allocate resources wisely: Ensure that your team has the people, technology, and external expertise required to handle the increased data load for Form PF reporting.
3. Optimize processes: Leverage technology like the IVP Regulatory Reporting Solution to streamline and automate your data collection and reporting processes.
4. Monitor progress: Regularly review your progress to ensure you’re on track to meet compliance deadlines. Frequent check-ins will help you address emerging challenges before they become roadblocks.

Preparing for the Future

The changes to Form PF reporting represent a significant shift in the regulatory environment. For investment managers and fund advisors, the key to successful compliance lies in early preparation, smart resource allocation, and leveraging technology to meet new data requirements more efficiently.

All of that can start with the IVP Regulatory Reporting Solution, which is designed to help your firm stay ahead of these changes, streamline compliance, reduce risk, and file Form PF confidently.

Learn more about the IVP Regulatory Reporting Solution or contact us at sales@ivp.in to schedule a live or online demo.