Compliance and filings

Form PF

Also called private fund reporting form.

Definition

Form PF is a confidential report filed with the SEC by registered investment advisers that manage private fund assets above a size threshold, disclosing fund-level information on assets, borrowing, investor concentration and exposures for use by the SEC and the Financial Stability Oversight Council. Exempt reporting advisers do not file it.

Updated October 9, 2026Checked against our editorial standards

Example

A manager registers with the SEC at Fund III. Its private fund assets exceed the Form PF reporting threshold, so it files an annual Form PF covering Funds I to III. For each fund it reports gross and net asset value, the balance drawn on the subscription line, the number of investors and the share of equity held by the five largest, and a breakdown of investors by type. The data comes from the administrator's year-end NAV and investor register. None of it is published. Had the manager stayed an exempt reporting adviser there would be no Form PF, though Form ADV Schedule D would still list each fund.

Confused with

Form ADV. Public, filed by every adviser including ERAs, about the adviser's business. Form PF is confidential, filed only by registered advisers above the threshold, about the funds' risk profile.

Form D. Filed per offering when a fund raises. Form PF is filed by the adviser about funds already running.

In practice

Most venture and private equity advisers that file do so annually; larger hedge fund advisers file more often and in more detail. Recent amendments added event-driven reports for larger private equity advisers, triggered by events such as an adviser-led secondary or the removal of a general partner. The practical burden is reconciliation: the figures must tie to the audited statements and to Form ADV, and the SEC compares them.

Related terms

Form ADVForm ADV is the uniform form that investment advisers, including most venture and private equity fund managers above the exempt reporting threshold, file with the SEC to register or report, disclosing their business, ownership, conflicts and, in Schedule D Section 7.B, each private fund they advise along with its auditor, administrator and prime broker.
Exempt reporting adviser (ERA)An exempt reporting adviser (ERA) is an investment adviser that relies on the Advisers Act venture capital fund exemption or the private fund adviser exemption, for advisers solely to private funds with under $150 million in US regulatory assets under management, and therefore files a reduced Form ADV with the SEC instead of registering as an investment adviser.
Subscription line (capital call facility)A subscription line is a revolving credit facility, secured on the limited partners' uncalled commitments and the general partner's right to call them, that a fund draws to pay for investments and expenses before calling capital from LPs and repays from the later capital call.
NAV (net asset value)NAV, net asset value, is the value of a fund's assets, with investments carried at fair value, less its liabilities at a reporting date, and equals the total of all partners' capital accounts.