Private Funds: SEC, CFTC Joint Proposal to Amend Form PF

KPMG insights: Form PF reporting has shown that the private fund industry is evolving in terms of business practices, complexity of fund structures, and investment strategies and exposures. These changes have prompted the capital markets regulators to propose enhancements to the Form PF reporting requirements to better understand the scope of potential risk to the financial markets. Following proposed amendments to Form PF issued in January 2022 (see KPMG Regulatory Alert), the SEC and CFTC have now collaboratively proposed additional amendments to Form PF that look to expand upon reporting requirements especially for large hedge fund advisers. Key areas include investment exposures (including cryptocurrencies), open and large positions, and borrowing and financing arrangements. Volatility in the cryptocurrency markets has raised regulatory concerns, and the agencies note that digital assets is now a common investment strategy pursued by hedge funds.