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Form PF
Frequently Asked Questions

The staff of the Division of Investment Management has prepared the following responses to questions related to Form PF and expects to update this document from time to time to include responses to additional questions. These responses represent the views of the staff of the Division of Investment Management. They are not a rule, regulation, or statement of the Commission, and the Commission has neither approved nor disapproved this information.  A paper version of the Form PF can be found at: http://www.sec.gov/about/forms/formpf.pdf.

Section A: General Filing Information

Q. A.1:I have a related person that is registered as an investment adviser and identified on my or my related person’s Form ADV as a relying adviser or special purpose vehicle (“SPV”) in reliance on the no action letter issued to the American Bar Association on January 18, 2012. How do I include such related person in Question 1(b) given that the related person does not have a separate CRD or SEC file number?
A. A.1:

We have upgraded the Private Fund Reporting Depository to allow filers to add a relying adviser or SPV as a related person on Form PF in Question 1(b).  Filers may now check a box (or use a special tag in an XML submission) indicating that the listed adviser is a relying adviser or SPV on the Form PF.  (Updated November 20, 2012) 

 
Q. A.2:I am a registered adviser with more than $1 billion attributable to liquidity funds and money market funds that filed my initial report on Form PF before July 16, 2012. In programming our internal systems to report the information required by Form PF to meet our filing deadline, we made assumptions regarding how to respond to certain questions in the Form, some of which may be inconsistent with the guidance that has since been provided by the Staff. Should I amend the report that I’ve already filed regarding liquidity funds before my next quarterly filing obligation?
A. A.2:The Staff would not object if you do not amend the report you filed to meet your July 16, 2012 filing deadline if the assumptions you made regarding how to respond to certain question were inconsistent with the guidance that has since beenprovided by the Staff. You should reflect the Staff guidance in future required reports and, in your next required filing, note in Question 4 any assumptions made in your initial filing that were inconsistent with the Staff guidance. (Posted July 19, 2012)
 
Q. A.3:I am a registered adviser with more than $5 billion in assets under management attributable to hedge funds that, as a result of the June 15, 2012 compliance date of Form PF, is required to file my initial report on Form PF before August 29, 2012. In programming our internal systems to report the information required by Form PF to meet our filing deadline, we made assumptions regarding how to respond to certain questions in the Form, some of which may be inconsistent with the guidance provided by the Staff after we programmed our internal systems to meet our initial filing deadline. Should I delay filing my report regarding hedge funds until I can reprogram my internal systems to reflect the Staff guidance?
A. A.3:You should meet your initial filing deadline. However, the Staff would not recommend enforcement action under section 207 of the Advisers Act if a large hedge fund adviser required to comply with the June 15, 2012 compliance date of Form PF is unable to incorporate the guidance provided by the Staff prior to filing its initial report, provided that: (i) the adviser’s assumptions in completing its initial report were reasonable based on the facts and circumstances governing at the time its reporting system was being developed, (ii) the assumptions or other approaches taken by the adviser in reporting information on Form PF that are inconsistent with Staff guidance are identified in Question 4, and (iii) future required reports reflect the Staff guidance. (Posted July 19, 2012)
 
Q. A.4:One of my reporting funds has been issued a CFTC Interim Compliant Identifier (“CICI”). May I use the CICI in response to questions on Form PF that request the reporting fund’s LEI?
A. A.4:Yes. The CFTC has designated DTCC-SWIFT as the provider of CICIs to certain market participants under the CFTC’s jurisdiction, including swap counterparties. The CFTC has stated that it expects that assigned CICIs will transition into the LEIs assigned to market participants when the global LEI system is established by an internationally-recognized setting body. See CFTC Announces Designation of DTCC-SWIFT as the Provider of CFTC Interim Compliant Identifiers, Release: PR6310-12 (July 24, 2012). (Posted November 20, 2012)
 
Q. A.5:Am I required to identify all of my related persons in Question 1(b)?
A. A.5:No. Form PF permits (but does not require) related persons to report on a single Form PF information with respect to such related persons and the private funds they advise as a matter of convenience for affiliated entities. See Instruction 2. You are only required to identify a related person in Question 1(b) if you are reporting information on your Form PF with respect to that related person. (Posted March 8, 2013)
 
Q. A.6:I advise a private fund, but I do not provide continuous and regular supervisory or management services to such private fund in accordance with Instruction 5.b.(3) for Form ADV, Part 1A (e.g., because I provide advice to the private fund on a non-discretionary basis and am not responsible for arranging or effecting the purchase or sale of securities I recommended).   Am I required to report such private fund on Form PF?
A. A.6:The Staff would not recommend enforcement action under section 207 of the Advisers Act if you do not report such private fund on Form PF.  However, pursuant to Form ADV, Part 1A, Note to Item 7.B, you would be obligated to report the private fund on Form ADV, section 7.B.1 if the private fund is not reported on Form ADV, section 7.B.1 by another adviser. (Posted April 25, 2013)
 
Q. A.7:Instruction 15 requires that I provide monetary value responses by rounding to the nearest thousand. When rounding to the nearest thousand, should I also truncate the response?
A. A.7:No. An example of rounding to the nearest thousand would be reporting “$1,111,000” to represent an actual monetary value of $1,111,111.  You should not truncate this response to “$1,111.” (Posted August 8, 2013)
 
Q. A.8:Instruction 10 of Form PF specifies that I must update my Form ADV to include a private fund in order for the private fund to be reported on Form PF.   It also states that if I have submitted the annual updating amendment to my Form ADV for the year before I am ready to submit my Form PF report, then I should file an other-than-annual amendment to my Form ADV to add a new private fund.  When filing the other-than-annual amendment to my Form ADV to add a new private fund, am I required to update each of the other questions in my Form ADV?
A. A.8:Generally, no.  If you are filing an other-than-annual amendment to your Form ADV for the sole purpose of generating a private fund identification number to add a new private fund to your Form PF report, you are only required to complete and file Form ADV Section 7.B.1 for the new private fund.  However, you should review General Instruction number 4 of Form ADV to evaluate when other amendments to Form ADV must be made. (Posted August 8, 2013)
 
Q. A.9:One of my reporting funds was liquidated during the reporting period.  Am I required to report information regarding that fund in my Form PF report for such reporting period?
A. A.9:Yes.  If a reporting fund was in existence during a reporting period for which you are submitting a Form PF report, you must include that fund in your report for such reporting period.  For questions that ask for responses based on the data reporting date (e.g., Questions 8 -16), you may enter “0” or “N/A,” as applicable, because the fund has been liquidated before the relevant data reporting date.   For questions related to the entire reporting period (e.g., Question 17 and 24), however, you should respond appropriately.  You should note in Question 4 that the reporting fund has been liquidated to provide context to your responses.   (Posted August 8, 2013)
 

Section B: Hedge Funds

Q. B.1:The Form specifies that a commodity pool is categorized as a hedge fund for reporting purposes. Under CFTC interpretations, a private fund that holds a single commodity interest position may be a commodity pool. Am I required to treat a private fund as a commodity pool if such private fund’s commodity interest positions are de minimis?
A. B.1:You should not categorize a private fund as a commodity pool for reporting purposes if the private fund’s commodity interest positions satisfy either of the de minimis tests in Regulation 4.13(a)(3)(ii) issued by the CFTC. Accordingly, you would only have to categorize such a private fund as a hedge fund if it otherwise meets the definition of a hedge fund (i.e., it may charge a performance fee, employ large amounts of leverage, or sell assets short). (Posted June 8, 2012)
 
Q. B.2:A hedge fund is defined generally to be any private fund that has the ability to pay a performance fee to its adviser, borrow in excess of a certain amount, or sell assets short.   If I advise a private fund that previously did not meet this definition, but later does meet this definition (because, for example, its fund documents change to include the ability to engage in short selling), must I change how I categorize that fund for reporting purposes and does it affect whether I am a large hedge fund adviser?
A. B.2:

Yes, the categorization of a private fund as a hedge fund may change from reporting period to reporting period, which in turn may affect whether you are a large hedge fund adviser with respect to a particular reporting period.  With respect to any fiscal quarter, a private fund should be categorized as a hedge fund if it met the definition of a hedge fund as of the last day of any month in the fiscal quarter immediately preceding your most recently completed fiscal quarter.  See Instruction 3.  See also definition of qualifying hedge fund.

For example, you are an adviser with a December 31 fiscal year end whose only client is a private fund with $1.6 billion in assets that does not and did not previously meet the definition of a hedge fund; however, on July 18, the characteristics of the private fund change such that going forward it meets the definition of a hedge fund (and also a qualifying hedge fund).  In this instance, for the fiscal quarters ending March 31, June 30, and September 30, you would not be a large hedge fund adviser with a quarterly filing obligation and the private fund would not be a qualifying hedge fund for reporting purposes. In accordance with Instruction 3, at the beginning of a fiscal quarter, you would determine whether you have a quarterly hedge fund reporting obligation with respect to that fiscal quarter by looking back to the immediately preceding fiscal quarter.  For example, for purposes of your third quarter ending September 30, at the beginning of that quarter on July 1, you would look back to the last day of the month for April, May, and June to determine if the private fund was a hedge fund. Similarly, in accordance with the qualifying hedge fund definition, this private fund would not be a qualifying hedge fund for reporting purposes for the quarter ending March 31, June 30, and September 30. 

You would, however, be a large hedge fund adviser subject to a quarterly filing obligation with respect to your fourth fiscal quarter ending December 31 because the private fund meets the definition of a hedge fund on July 31 (i.e., the last day of any month in the third quarter) and you have over $1.5 billion in hedge fund assets under management on that date. (Posted June 8, 2012)

 
Q. B.3: For purposes of Form PF (and Form ADV), a hedge fund is defined to include any private fund that may have “gross notional exposure” in excess of twice its net asset value . Does the term “gross notional exposure,” which is undefined, have the same meaning as the defined term “gross notional value?”
A. B.3:Yes. (Posted June 29, 2012)
 

Section C: Liquidity Funds

Q. C.1:I advise a private fund that meets the definition of both a liquidity fund and a hedge fund. Am I required to report that private fund as both a liquidity fund and a hedge fund?
A. C.1:Yes. The definitions of a liquidity fund and a hedge fund are not mutually exclusive and, as a result, certain private funds may meet the definition of both. See Glossary of Terms. For such a private fund, you should include it in the calculation of hedge fund assets under management and liquidity fund assets under management and complete each section applicable to hedge funds and liquidity funds. For example, a filer that qualifies as both a large hedge fund adviser and a large liquidity fund adviser would report information on a private fund that meets the definition of a liquidity fund and a hedge fund in sections 1, 2, and 3. (Posted June 8, 2012)
 
Q. C.2:If I advise a private fund that meets the definition of both a liquidity fund and a hedge fund and I am therefore required to complete sections applicable to hedge funds and liquidity funds with respect to such fund, how should I categorize the private fund in Schedule D of my Form ADV?
A. C.2:To enable you to be able to complete sections that relate to two different categories of funds, you should categorize the private fund that meets the definition of both a liquidity fund and a hedge fund as “other” on your Form ADV, Schedule D. If you need to change the categorization of a private fund on your Form ADV, Schedule D, you should file an other-than-annual amendment to your Form ADV to reflect such change before you file your Form PF. See Instruction 10. (Posted November 20, 2012)
 

Section D: Private Equity Funds

Q. D.1:I advise a private fund that would be categorized as a private equity fund, except for the fact that the fund documents allow the fund to either employ large amounts of leverage or sell assets short. The fund does not in fact, nor does it intend to, incur leverage or short any assets. May I treat this private fund as a private equity fund instead of as a hedge fund for reporting purposes?
A. D.1:

No. In adopting the Form, the Commission considered, but did not accept, commenters’ arguments that the leverage and shorting characteristics in the definition of “hedge fund” should focus on actual or contemplated use, rather than potential use. See Investment Advisers Act Release No. 3308, text accompanying footnote 78. However, if the private fund you advise is represented to investors as a type of fund other than a hedge fund (i.e., as a private equity fund, real estate fund or venture capital fund), you may, and the staff recommends that you do, include a note in Question 4 indicating the category of private fund that you believe better describes the fund and indicate why the reporting fund meets the definition of a hedge fund. (Updated February 12, 2014)

 

Section E: Aggregation

Q. E.1:Instruction 5 requires me to aggregate parallel funds, dependent parallel managed accounts, and master-feeder funds that I advise to determine whether I meet the various reporting thresholds of the Form. It also states that I must treat any private fund or parallel managed account advised by any of my related persons as though it were advised by me, unless the related person is separately operated. Do I include parallel managed accounts advised by a related person that is not separately operated when determining whether the parallel managed accounts are dependent parallel managed accounts?
A. E.1:

Yes. To determine whether you meet any reporting threshold as a result of Instruction 5, (i) first you should attribute to yourself any private funds and parallel managed accounts advised by a related person that is not separately operated and (ii) then you may subtract from the total amount any aggregated parallel managed accounts that are not dependent parallel managed accounts.

For example, assume you advise Hedge Fund ABC with assets of $600 million and your related person that is not separately operated advises Hedge Fund XYZ with assets of $300 million and Managed Account 1 with assets of $800 million.

When determining your assets under management for determining whether you meet any reporting threshold, you would first attribute to yourself all of these assets for a total of $1.7 billion. Next, you would determine whether the Hedge Funds or Managed Account are parallel and, if so, subtract the Managed Account if it is not a dependent parallel managed account.

If Hedge Fund ABC and Hedge Fund XYZ pursue substantially similar investment objectives and strategies and maintain substantially the same positions as one another and Managed Account 1, then Managed Account 1 is a dependent parallel managed account of the parallel fund structure of Hedge Fund ABC and Hedge Fund XYZ. This is because the assets of Managed Account 1 ($800 million) are less than the combined assets of the parallel fund structure ($900 million). As a result, you would be a large hedge fund adviser with $1.7 billion of assets under management attributable to hedge funds.

If, however, Hedge Fund XYZ is not a parallel fund of Hedge Fund ABC, but Managed Account 1 is a parallel managed account with respect to Hedge Fund ABC, then Managed Account 1 is not a dependent parallel managed account of either Hedge Fund ABC or Hedge Fund XYZ. This is because the assets in Managed Account 1 ($800 million) are greater than Hedge Fund ABC ($600 million). As a result, you would not be a large hedge fund adviser because you would only have $900 million assets under management attributable to hedge funds. (Posted June 8, 2012) 

 
Q. E.2: Instruction 5 states that, for purposes of reporting information in Sections 1b, 1c, 2b, 3 and 4, I am not required to report information regarding parallel managed accounts (except in Question 11). If I choose to report information regarding parallel managed accounts when responding to questions related to a reporting fund, how can I indicate to you this reporting method?
A.
E.2:
We prefer that you not include information regarding parallel managed accounts (except in Question 11). If, however, you decide to include such information the staff recommends that, in Question 4, you indicate that you are reporting information regarding your parallel managed accounts when responding to questions related to a reporting fund other than Question 11. (Posted February 12, 2014)
 
Q. E.3: See Q.11.1 below. (Posted July 19, 2012)

Section F: Fund of Funds

Q. F.1:Instruction 7 allows a filer to complete only section 1b for disregarded private funds (i.e., a private fund that (i) invests substantially all of its assets in the equity of private funds for which the filer is not the adviser (“external funds”) and (ii) aside from such external fund investments, holds only cash and cash equivalents and instruments acquired for the purpose of hedging currency exposure). May a filer treat as a disregarded private fund a private fund that invests its assets in the equity of private funds for which the filer is the adviser (“internal funds”) in lieu of, or in addition to, external funds and, therefore, rely on Instruction 7 to complete only section 1b for such fund?
A. F.1:Yes, a filer may treat as a disregarded private fund a private fund that (i) invests in internal funds in lieu of, or in addition to, external funds and (ii) aside from such underlying internal and external fund investments, holds only cash and cash equivalents and instruments acquired for the purpose of hedging currency exposure. As a result, a filer would only be required to complete section 1b for such disregarded private fund. (Posted June 8, 2012)
 
Q. F.2:Instruction 7 specifies that a filer may disregard certain private funds and a private fund’s equity investments in other private funds. If I only advise disregarded private funds (or private funds whose investments may be disregarded) under Instruction 7, am I required to report on Form PF?
A. F.2:Yes, you are required to file a Form PF if the private fund assets you and your related persons manage collectively meet or exceed $150 million in private fund assets under management. Disregarded private funds and disregarded investments would not, however, be included for purposes of determining whether the filer meets any of the large private fund adviser thresholds or the $5 billion compliance date thresholds. See Investment Advisers Act Release No. 3308, text accompanying footnote 128. Accordingly, a filer advising only disregarded private funds that invest only in external funds would report annually and complete only sections 1a and 1b of the Form. (Posted June 8, 2012)
 
Q. F.3:Instruction 7 allows me to exclude disregarded private funds (i.e., funds of funds) and any private fund’s equity investments in other private funds for reporting purposes. If I chose to disregard a private fund or an equity investment in other private funds in accordance with this Instruction, should I exclude these disregarded assets when reporting the fund’s assets in Questions 3, 8, 9, and 10 in section 1b?
A. F.3:Yes, in such case you should exclude disregarded private funds and any other private fund’s equity investments in other private funds with respect to reporting the breakdown of your regulatory assets under management and net assets in Question 3 and the reporting fund’s gross asset value in Question 8 and net asset value in Question 9. You are, however, required to report the value of the reporting fund’s investments in the equity of other private funds in Question 10, even if the reporting fund is a disregarded private fund. (Posted November 20, 2012)
 
Q. F.4:If I disregarded a private fund or equity investments in other private funds when reporting the fund’s assets in Questions 3, 8, and 9, do I also disregard such assets when responding to Question 15 and 16?
A. F.4:No.  Unlike the other questions that ask about the reporting fund’s underlying assets, Questions 15 and 16 ask information about the reporting fund’s beneficial owners.   (Posted March 8, 2013)
 
Q. F.5: Instruction 7 states that a filer may disregard any private fund’s equity investments in other private funds when reporting on Form PF. Should I indicate to you whether I include or disregard the reporting fund’s investment in other private funds when reporting on Form PF?
A. F.5: We recommend that you indicate in Question 4 whether you disregard or include a reporting fund’s investment in other private funds for purposes of reporting on Form PF. (Posted February 12, 2014)

Section G: Definitions

Q. G.1:The definition of “net asset value” refers to a fund’s regulatory assets under management minus any outstanding indebtedness or other accrued but unpaid liabilities. When we report a fund’s net assets value to investors, however, we do not deduct deferred compensation amounts that might otherwise be deemed a liability for accounting purposes if the amount attributable to such compensation remains in the fund and shares in the fund’s profits and losses, treating such amount similar to an equity investment by an investor. For purposes of responding to various questions in the Form that refer to the fund’s “net asset value,” may we deduct deferred compensation liabilities even though we do not do so in the circumstance described above?
A. G.1:We would not recommend enforcement action under section 207 of the Advisers Act if, for purposes of responding to various questions in the Form that refer to a fund’s net asset value, you do not deduct the liabilities associated with deferred compensation, including deferred management fees, incentive fees, or other incentive compensation, in accordance with the facts you describe above, provided that you note in Question 4 that you are not deducting deferred compensation amounts when reporting the net asset value of a fund. (Posted July 19, 2012)
 
Q. G.2:How should I treat short positions, derivatives, repurchase agreements, total return swaps, and other financial instruments for purposes of calculating regulatory assets under management in Question 3 and for purposes of calculating a reporting fund’s gross asset value in Question 8?
A. G.2: If the private fund has a balance sheet, you may rely on the gross assets reflected on the balance sheet to calculate “regulatory assets under management” and “gross asset value.”  Accordingly, you need not assess the value of these financial instruments in a manner different from that required under the applicable accounting standard.  See Frequently Asked Questions on Form ADV and IARD (Form ADV: Item 7.B).

For example, when determining whether to include short positions, the short position should be included when it is an asset on the balance sheet in accordance with the applicable accounting standard. Typically, a short sale will be recorded as a short sale liability (because the fund has an obligation to replace the security) together with an asset for the proceeds received or due from the counterparty (e.g., cash received or due from a broker). In that case, the short sale liability would neither be included as an asset nor deducted from assets in the calculation of “gross asset value,” although the proceeds received would be included in “gross asset value.” However, if the fund takes a short position using a derivative, the derivative itself may have a positive fair value and be recorded as an asset. In this case, the short position would be included as an asset in the calculation of “gross asset value.”  See Investment Advisers Act Release No. 3221, footnote 83. (Posted March 8, 2013) 

 

Section H: Master-Feeder Arrangement

Q. H.1:If I reported private funds in a master-feeder arrangement on an aggregated basis for purposes of Form ADV, Section 7.B.1, am I required to report the master-feeder arrangement on an aggregated basis on Form PF?
A. H.1:Yes.  In order to report the funds in such master-feeder arrangement separately on Form PF, you should file an other-than-annual amendment to your Form ADV to reflect such change before you file your Form PF.  (Posted March 8, 2013)
 
Q. H.2:If I elect to aggregate a master-feeder arrangement for reporting purposes in accordance with Instruction 6, how do I respond to questions regarding the investors of the master-feeder arrangement?
A. H.2:Instruction 6 specifies that, if you are reporting a master-feeder arrangement on an aggregated basis, you must treat the aggregated funds as if they were all one private fund.  Accordingly, you should collapse the master-feeder structure and aggregate all investors in the master-feeder arrangement (but do not count the feeder funds themselves as investors) when responding to questions about investors of the master-feeder arrangement.  For example, in a master-feeder arrangement where there are no direct investors in the master fund other than the feeder funds, you should report the approximate percentage beneficially owned by the investors of the feeder funds as calculated on an aggregate basis when responding to Questions 15 and 16 regarding beneficial ownership and you should report the liquidity of the investors of the feeder funds when responding to Question 50 about investor liquidity. (Posted March 8, 2013)
 

Question-Specific FAQs

Question 4

Q. 4.1:What kind of information should I provide in response to Question 4?
A. 4.1:Question 4 allows you to provide assumptions that you have used in responding to any of the Questions on the Form because the Form does not accommodate explanations to accompany each question. For example, if you have identified an ambiguity in a Question or if you provide a response to a Question that, while consistent with your internal methodologies, is inconsistent with industry practice, you may note that in Question 4 . The Question is designed to provide the staffs of the Commission and the Office of Financial Research with context to your responses. (Posted June 29, 2012)
 

Question 11

Q. 11.1:I manage a parallel managed account that holds derivatives in its investment portfolio. When calculating the value of the parallel managed account to determine whether it is a dependent parallel managed account subject to aggregation according to Instruction 5 or reporting the value of the parallel managed account related to a reporting fund in Question 11, am I required to calculate the gross notional value of the derivatives held in the parallel managed account, even if I report such derivatives at market value to my clients?
A. 11.1:No. When calculating the value of a parallel managed account for purposes of either determining whether it is a dependent parallel managed account that is aggregated with the reporting fund or reporting its value in Question 11, you should use the market value of the derivatives held in the parallel managed account, instead of the gross notional value, if that is how the value of the account is reported to the account holder. (Posted July 19, 2012)
 

Question 12

Q. 12.1:Questions 12 and 43 ask for information regarding the value of a fund’s borrowings. In addition to traditional lending activity, what other types of transactions should I consider to be borrowings for purposes of these questions?
A. 12.1:For purposes of Questions 12 and 43, borrowings should include secured borrowings, unsecured borrowings, as well as synthetic borrowings, but would not include leverage embedded through the use of derivatives. The types of borrowing that would be reported include, but are not limited to: (i) selling securities short, (ii) securities lending transactions, (iii) reverse repurchase agreements, (iv) transactions in which variation margin is owed, but as a result of not reaching a certain set threshold, has not been paid by a fund, or (v) transactions involving synthetic borrowings (e.g., total return swaps that meet the failed sale accounting requirements). (Posted July 19, 2012)
 
Q. 12.2:If selling securities short is considered a borrowing for purposes of Questions 12 and 43, how should I calculate the value of a short transaction?
A. 12.2:

In determining the value of a borrowing that includes selling a security short, “value” means the value that is reported internally and to current and prospective investors of the fund that is selling the security short. See Instruction 15.

For example, assume on the first data reporting date a fund borrows $100 from its prime broker to purchase $100 worth of Security A and borrows $50 worth of Security B from its prime broker to sell short, and then, on the second data reporting date, Security A is marked to $120, Security B is marked to $60, and the fund posts to the prime broker $8 in cash collateral. For purposes of calculating the value of the fund’s borrowings for Question 12 and 43, the fund’s borrowings on the first data reporting date would be $150, which consists of the $100 borrowed from the prime broker to purchase Security A and $50 from the short sale of Security B. With respect to the second data reporting date , the value of the fund’s borrowings would be $160, which consists of the $100 from the purchase of Security A and the $60 from the short sale of Security B and excludes the $8 collateral pledged by the fund in accordance with the instructions to Questions 12 and 43, which require that a fund not net out amounts that the fund loans to creditors or the value of collateral pledged to creditors . (Posted July 19, 2012) 

 
Q. 12.3: Question 12 asks for certain information regarding the value of the reporting fund’s borrowings. I report similar information for qualifying hedge funds in Question 43. Should I also complete Question 12 for these qualifying hedge funds?
A. 12.3:

No. You are not required to complete Question 12 for any reporting fund with respect to which you are answering Question 43 in Section 2b. If you answer Question 43 with respect to a reporting fund, you should leave each part of Question 12 blank. (Posted February 12, 2014)

Question 13

Q. 13.1: See Question 44 below. (Posted March 8, 2013)
 
Q. 13.2: Question 13(a) asks if the reporting fund has any outstanding derivatives positions. Question 13(b) instructs that, if you responded “yes” to Question 13(a), you provide the aggregate value of all derivatives positions of the reporting fund. I report similar information for qualifying hedge funds in Question 44. Should I also complete Question 13 for these qualifying hedge funds?
A.
13.2:

No. You are not required to complete Question 13 for any reporting fund with respect to which you are answering Question 44 in Section 2b. If you answer Question 44 with respect to a reporting fund, you should leave each part of Question 13 blank. (Posted February 12, 2014)

 

Question 14

Q. 14.1:When filing my annual update or a quarterly update for my fourth fiscal quarter, Question 14 requires me to provide a summary of the reporting fund’s assets and liabilities categorized using the hierarchy described in the question.  Am I required to categorize each asset and liability in accordance with this hierarchy?
A. 14.1:No.  You are only required to categorize in accordance with the hierarchy described in Question 14 those assets and liabilities that are required to be presented in the reporting fund’s financial statements at fair value (regardless of whether the reporting fund is actually audited).  (Posted April 25, 2013)
 
Q. 14.2:In the cost-based column in Question 14, should I include those assets and liabilities that are not reported at fair value and therefore are not reflected in the fair value hierarchy, such as certain receivables and payables?
A. 14.2:Yes. You should include assets and liabilities in the cost-based column that would be presented in a fund’s financial statements using a measurement attribute other than fair value.  See Investment Advisers Act Release No. 3308, footnote 210.  As a result, the sum of the amounts entered in the assets row of Question 14 should approximate the reporting fund’s gross assets reported in Question 8 at the time of reporting (except for funds with uncalled commitments included in their gross assets, in which case the sum of the values in the assets row of Question 14 will equal the gross assets minus the uncalled commitments amount because such amounts are not reflected as assets on a fund’s balance sheet).  Also, the sum of the amounts in the liabilities row of Question 14 should approximate the total liabilities reported on the fund’s financial statements. If an asset or a liability is reported as representing fair value, but the fair value of the asset or liability is equal to its cost, then that asset or liability should still be categorized in the fair value hierarchy and should not be included in the cost-based column.  (Updated February 12, 2014)
 
Q. 14.3: Should I include cash and cash equivalents when providing a summary of a reporting fund’s assets and liabilities in Question 14?
A. 14.3: Yes, according to FAQ 14.2, the sum of the amounts entered in the assets row of Question 14 should generally approximate the reporting fund’s gross assets reported in Question 8 at the time of reporting (except in the case of funds with uncalled commitments). Accordingly, cash should be included in the cost-based column and cash equivalents should be included in the applicable column in the fair value hierarchy or the cost-based column, depending on the nature of the cash equivalents. (Posted February 12, 2014)

Question 20

Q. 20.1: Question 20 requires that I indicate which investment strategies best describe the reporting fund’s strategies. For each strategy, I am required to provide a good faith estimate of the percentage of the reporting fund’s net asset value represented by that strategy. Instruction 15 states that, for Question 20, the numerator that I use to determine the percentage of net asset value must be measured on the same basis as gross asset value. In completing Question 20 for a reporting fund that has gross assets in excess of its net assets, should the total of my answers in the “% of NAV” column add up to more than 100%?
A. 20.1: Yes, the responses to the “% of NAV” column should generally add up to more than 100%. You should note that the requirement in Instruction 15 regarding the use of gross assets also applies to Questions 21, 25, 28, 35 and 57. (Posted February 12, 2014)

Question 22 and 23

Q. 22.1:Questions 22 and 23 ask for information about the counterparty credit exposure of a fund. Should I include the value of securities held by a fund’s custodian or prime broker or the value of any open futures positions or the amount of excess margin at a futures commission merchant (“FCM”) when responding to these questions?
A. 22.1:As the instructions to Questions 22 and 23 indicate, these questions are designed to report over-the-counter derivatives positions, loans, and loan commitments. As a result, you should not include assets held in custody at any custodian or prime broker (that are not otherwise held as collateral by such custodians or prime brokers as derivative counterparties or lenders), nor should you include futures positions or excess margin held at an FCM in the account of the private fund when responding to these questions. (Posted July 19, 2012)
 
Q. 22.2:Should a filer include redeeming investors as counterparties for purposes of Question 22?
A. 22.2:No. Investors that are owed redemption proceeds are not credit counterparties for purposes of Question 22. (Posted July 19, 2012)
 
Q. 22.3:Questions 22 and 23 ask for the top five counterparties to which a fund has the greatest counterparty credit exposure and the top five counterparties which have the greatest counterparty credit exposure to the fund, respectively. If a private fund that I manage uses five different counterparties to engage in securities lending, short transactions, reverse repurchase agreements, repurchase agreements, and over-the-counter derivatives transactions that are not centrally cleared, how should I account for these transactions in Questions 22 and 23?
A. 22.3:

Questions 22 and 23 focus on a fund’s counterparty credit exposure and the instructions to these questions state that you should not take into account any margin posted by or to the counterparty. As a result, you should report the following for each type of transaction identified:

  • Securities lending – the current market value of the securities the fund has lent to the counterparty in Question 22. You do not include any collateral that it has received from the counterparty;
     
  • Short transactions – the current market value of the security that the fund has sold short in Question 23(see Q.12.2 above for more details). You do not include any cash proceeds received as a result of the transaction;
     
  • Reverse repurchase agreements – the amount of cash received from the counterparty in Question 23. You do not include the amount of any collateral posted to the counterparty;
     
  • Repurchase agreements – the amount of cash lent to the counterparty in Question 22. You do not include the amount of any collateral posted by the counterparty;
     
  • Non-cleared derivatives transactions with an unrealized gain – the amount of the unrealized gain on the transaction in Question 22. You exclude the amount of any collateral posted by the counterparty or the fund; and
     
  • Non-cleared derivatives transactions with an unrealized loss – the amount of the unrealized loss on the transaction in Question 23. You exclude the amount of any collateral posted by the counterparty or the fund.

(Posted July 19, 2012)

 
Q. 22.4:A private fund that I manage has open over-the-counter derivatives positions with two swap dealers that are unaffiliated with one another. The fund’s set-off positions with the first swap dealer have a net gain of $50,000, but the set-off positions with the second swap dealer have a net loss of $25,000. How should I account for these positions for purposes of Questions 22 and 23?
A. 22.4:You should not net positions across different counterparties unless such entities are affiliated with one another and netting is permitted by the instructions to Question 22 or 23. Because the fund you manage is not permitted to net its positions across the two unaffiliated swap dealers, you would report the $50,000 position in Question 22. Further, the $25,000 unrealized loss position would be reported in Question 23 because the second swap dealer has a net counterparty credit exposure to the fund . (Posted July 19, 2012)
 
Q. 22.5:The instructions to Question 22 and 23 state that I should not take into account margin posted by or to a counterparty for purposes of identifying the top counterparties to which a fund has the greatest counterparty credit exposure and the top counterparties that have the greatest counterparty credit exposure to the fund, respectively. Does this instruction mean I should not take into account either initial margin or variation margin?
A. 22.5:

For calculating responses for Questions 22 and 23, you should not include amounts attributable to either initial margin or variation margin. You would, however, include initial margin and variation margin as appropriate for purposes of responding to Questions 36 and 37, which are based on the counterparties identified in Questions 22 and 23, respectively, and must be completed by large hedge fund advisers for each qualifying hedge fund.

For example, assume a fund you manage has entered into a derivative position with a counterparty with whom you have an ISDA agreement in place and the following sequence of events occurs: (i) the fund posts $1 million of initial margin to the counterparty; (ii) the fund incurs a $400,000 unrealized gain on the derivative position; and (iii) the fund then receives $200,000 of variation margin from the counterparty. For purposes of Question 22, you should report the $400,000 unrealized gain and disregard the collateral. For purposes of Question 23, you would not report any amount for this counterparty because the fund has a mark-to-market gain. If you are a large private fund adviser and the fund is a qualifying hedge fund required to complete Section 2b, you would report that the fund has received $200,000 in Question 36 because the counterparty paid $200,000 to the fund. You would not, however be required to report any amount in Question 37 because the counterparty was not listed in Question 23. (Posted July 19, 2012)

Question 24

Q. 24.1:One of our reporting funds has entered into an exchange-traded futures contract through an FCM that is a clearing member of the exchange. How should I report this transaction for purposes of Question 24 and Question 39?
A. 24.1:

For purposes of Question 24, the transaction would be classified as a derivative and therefore included in response to Questions 24(b) and 24(c). For purposes of Question 24(b), because the transaction was traded on an exchange , the transaction would be included under the sub-heading “On a regulated exchange or swap execution facility . ” In addition, because the transaction was cleared through the exchange, for purposes of Question 24(c), it would be included under the sub-heading “Cleared by a CCP.”

Question 39, however, asks whether the reporting fund “directly” cleared any transactions through a CCP. Because the fund is not a clearing member and it did not directly clear through the CCP, you would respond “No” to Question 39 if this is the reporting fund’s only derivative transaction. (Posted June 29, 2012)

 
Q. 24.2:How should I calculate the percentage of derivatives trade volume in Questions 24(b) and 24(c) for a fund?
A. 24.2:

In determining the trade volume percentage of derivatives trades for purposes of Questions 24(b) and 24(c), you should use the weighted-average of the notional amount of the aggregate derivatives transactions (except for options, in which case you would use the delta adjusted notional value, and interest rate derivatives, in which case you would use the 10-year bond equivalent) entered into by the fund during the reporting period.  For example, assume the reporting fund only entered into the following three trades during the reporting period: (i) purchased contracts of gold on the futures exchange worth $50,000, (ii) entered into an over-the-counter interest rate swap that was cleared by a CCP with a 10-year bond equivalent of $1,000,000, and (iii) purchased an over-the-counter call option that was not cleared by a CCP with a delta equivalent of $500,000.  You would compute the fund’s trade volume as follows:

  1. For Question 24(b), because the futures transaction was the only transaction that was traded on a regulated exchange or swap execution facility, the fund should report 3% ($50,000/$1,550,000) on the first line and 97% ($1,500,000/$1,550,000) on the second line.
     
  2. For Question 24(c), because the futures transaction and the interest rate swap were cleared by a CCP, the fund should report 68% ($1,050,000/$1,550,000) on the first line and 32% ($500,000/$1,550,000) on the second line.  (Posted March 8, 2013)
 
Q. 24.3:For Questions 24(b) and 24(c), I am reporting trade volume by using the weighted-average of the notional amount of the aggregate derivatives transactions, but have found it operationally difficult to provide the delta adjusted notional values for options and 10-year bond equivalents for interest rate derivatives.  May I instead use the gross notional values for such options and interest rate derivatives when calculating my responses to these questions?
A. 24.3:Yes, but you should provide a notation in Question 4 explaining the use of gross notional values. (Posted August 8, 2013)
 

Question 26

Q. 26.1:Questions 26 and 30 ask for hedge fund exposures to “listed equity derivatives. ” Does “listed” refer to whether the derivative is listed or whether the equity asset underlying the derivative is listed?
A. 26.1:The term “listed equity derivatives” refers to the fund’s exposures to derivatives for which the underlying asset is listed equities. For example, if a fund has purchased an over-the-counter option from a bank on the equity securities issued by a software company that are listed on a regulated exchange, you would include the delta adjusted notional value of the option under the sub-heading “other listed equity derivatives” identified under the “listed equity derivatives” asset class. (Posted June 29, 2012)
 
Q. 26.2:How should I account for a position of a fund that could accurately be classified in multiple sub-asset classes identified in Questions 26 and 30?
A. 26.2:Because the instructions to these Questions note that any particular position should only be included in a single sub-asset class, you should choose the sub-asset class that describes the position with the highest degree of precision. For example, a Canadian currency position should be included in the “non-U.S. currency holdings” sub-asset class even though the definition of “cash and cash equivalents” includes non-U.S. currencies. (Posted June 29, 2012)
 
Q. 26.3:The definitions for certain fixed-income asset and sub-asset classes in Questions 26 and 30 require us to include certain types of derivatives on the particular asset or sub-asset classes when measuring exposure for such asset or sub-asset class.  See “corporate bonds,” “convertible bonds,” “GSE bonds,” and “sovereign bonds”.   Should we also include derivative exposures when measuring exposures to each of the sub-asset classes under the “ABS/structured products” asset class (i.e., “MBS,” “ABCP,” “CDO/CLO,” “Other ABS,” and “Other structured products”)?
A. 26.3:Yes.  The instructions to Question 26 and 30 specify that you should include all exposure whether held physically, synthetically, or through derivatives.    For example, you should categorize a forward position on a mortgage-backed security in the “MBS” sub-asset class in the “ABS/structured products” asset class and report the notional amount of the forward position.   (Posted March 8, 2013)
 
Q. 26.4: Instruction 15 states that, unless otherwise specifically indicated, the value of derivatives (other than options) should be reported in terms of such derivatives’ gross notional value.  The definition of “interest rate derivative”, however, requires filers to present this information in terms of 10-year bond equivalents. How should I report a reporting fund’s exposure to interest rate derivatives in Questions 26 and 30?  
A. 26.4:Because Instruction 15 applies unless otherwise specifically indicated, you should follow the requirement in the definition and report the exposure of interest rate derivatives in terms of 10-year bond equivalents.  (Posted March 8, 2013)
 
Q. 26.5: Should I report the value of a reporting fund’s Reverse Repos as the Short Value (SV) in the “Repo” sub-asset class in Questions 26 and 30?
A. 26.5: Yes, the amount of cash borrowed via Reverse Repos should be considered the short value (SV) of Repos when reporting the exposures in Questions 26 and 30. You should carefully review the definitions of “Repo” and “Reverse Repo” in the Glossary of Terms. If a reporting fund sells a security with an agreement to repurchase such security at a later date at an agreed upon price, then such arrangement is defined as a “Reverse Repo” and is considered a borrowing. See also FAQ 12.1. On the other hand, if a reporting fund purchases a security together with an agreement to sell such security at a later date at an agreed price, then such arrangement is defined as a “Repo” and is not considered a borrowing. (Posted February 12, 2014)

Question 28

Q. 28.1:Questions 28 and 78 require large private fund advisers to provide a geographical breakdown of the investments held by certain private funds they advise. For purposes of these Questions, how should I treat, for example, a derivative in which the underlying asset is an equity security issued by a Canadian company that the private fund enters into with a French bank?
A. 28.1:In responding to Questions 28 and 78, you have flexibility to determine how to report the geographical area of investments. You are permitted to classify such investments in a manner that is consistent with your internal methodologies and the reporting of such information to investors. See Instruction 15. You may want to describe these assumptions in Question 4. For instance, in the example above, you could classify the geographical breakdown of such an investment as either exposure to North America or to Europe, depending on how you classify the exposure internally and report the information to investors, and you could note this treatment in Question 4. (Posted June 29, 2012)
 
Q. 28.2:Mexico is geographically considered to part of North America, but for purposes of our own risk assessments, we treat it as part of South America. May I report exposures to Mexican securities under the South America category in Questions 28 and 78?
A. 28.2:Where such flexibility is allowed, you can respond to Questions using your own internal methodologies provided the information is consistent with information you report internally and to investors and explain such methodologies in Question 4. See Instruction 15. As a result, if your internal risk assessments and reports to investors consistently treat exposures to Mexican securities as exposure to South America, then you may report any such investments under the “South America” category, and you may note such treatment in Question 4. (Posted June 29, 2012)
 

Question 30

See Question 26 above. (Posted June 29, 2012)
 

Question 35

Q. 35.1:When reporting a reporting fund’s relevant open positions, should I report a short position that represents more than 5% of the reporting fund’s net asset value as a negative value?
A. 35.1:Yes.  (Posted March 8, 2013)
 
Q. 35.2:Should we consider cash and cash equivalents to be a “position” for purposes of reporting open positions in Questions 35 and 57?
A. 35.2: No.  You should exclude cash and cash equivalents when responding to Questions 35 and 57.  The value of unencumbered cash should be reported in Question 33. (Posted August 8, 2013)
 

Question 36 and 37

See Question 22.5 above. (Posted July 19, 2012)
 

Question 38

Q. 38.1:When responding to questions regarding the rehypothecation of collateral and other credit support, either by the reporting fund for Question 38(a) or by such fund’s counterparties for Question 38(b), should I include cash collateral?
A. 38.1:No. (Posted November 20, 2012)
 

Question 39

See Question 24 above. (Posted June 29, 2012)
 

Question 42

Q. 42.1:Question 42 requires an adviser to report the effect of specific changes for different market factors on a reporting fund’s portfolio if the adviser regularly considers the specified market factor in formal testing in connection with the reporting fund’s risk management. Formal testing is described to mean that the adviser has implemented systems capable of simulating the effect of a market factor, not that the specific assumptions or changes identified under each market factor in the Question were actually used in testing. While I maintain systems that are capable of simulating a market factor as part of my risk management, I do not currently use those systems to test for the factors identified in Question 42 or, even if I do test for a particular market factor, I do not test for the specific changes in the market factor identified. How do I respond to Question 42?
A. 42.1:As indicated in the instructions to Question 42, advisers are only required to report on market factors that they believe are relevant to a fund’s portfolio and have the capacity to test using their current models or other systems. For instance, if you currently have models or other systems in place as part of the risk management systems for a reporting fund that have the ability to test changes in currency rates and you believe that currency rate changes are a relevant market factor to the fund’s portfolio, but you either do not test for changes in currency rates or you test for changes other than those specified in Question 42 (i.e., increase 5%, decrease 5%, increase 20%, and decrease 20%), then you are still required to provide a response to the currency rate market factor changes specified in Question 42. (Posted July 19, 2012)
 

Question 43

See Question 12 above. (Posted July 19, 2012)
 

Question 44

Q. 44.1:One of my reporting funds has entered into several derivatives transactions with a single swap dealer. If I have an ISDA agreement in place with the swap dealer that allows me to net across all my positions, how should I report these derivatives transactions for purposes of Question 44?
A. 44.1:

Question 44 requires you to report the aggregate “value” of all derivatives positions. Value is defined in Instruction 15 and requires that the fund report the gross notional value of its derivative positions without netting across positions. Instruction 15 defines “positions” and requires advisers to determine whether a set of legal and contractual rights constitutes a single “position” in a manner consistent with the fund’s internal recordkeeping and risk management procedures. In accordance with this Instruction, you may only net across your positions if doing so is consistent with your internal recordkeeping and risk management procedures, regardless of whether your ISDA agreement with the swap dealer allows netting.

Further in reporting the aggregate value of all derivatives positions in Question 44, you should not include any closed-out out positions, if those positions were closed out with the same counterparty and result in no credit or market exposure to the fund. (Posted July 19, 2012)

 
Q. 44.2:When reporting the aggregate value of all derivatives positions of a reporting fund in either Question 13(b) or Question 44, may I report a negative number?
A. 44.2:

No.  You should report the absolute value of outstanding derivatives position.  (Posted March 8, 2013)

 

Question 46

Q. 46.1:Does the guidance provided by the staff regarding borrowings for Question 12 and 43 above also apply to how borrowings should be interpreted for Questions 46 and 47?
A. 46.1:Yes.  See Question 12 above. (Posted August 8, 2013)
 
Q. 46.2: Question 46(a) requires an adviser to provide, for each qualifying hedge fund, the aggregate dollar amount of borrowings by and cash financing available to the reporting fund (including all drawn and undrawn, committed and uncommitted, lines of credit as well as any term financing). Question 43 requires that the qualifying hedge fund provide the value of the fund’s secured and unsecured borrowings. Should my response to Question 46(a) include the borrowings I reported in Question 43?
A. 46.2: Yes. Question 46(a) asks for current borrowings plus available cash financing. Generally, the response in Question 46(a) should be greater than or equal to the sum of the responses in Question 43 because Question 46(a) requests an amount that includes cash financing (e.g., lines of credit and term financing) available to the fund and the amount borrowed by the fund that is reported in Question 43. (Posted February 12, 2014)

Question 47

See Question 46 above. (Posted August 8, 2013)
 

Question 49

Q. 49.1:Questions 49(c) and 49(e) and Questions 63(b) and 63(d) ask about the percentage of a reporting fund’s net asset value that may be subjected, or is subject, to material restrictions on investor withdrawals/redemption.  When responding to these questions, should I take into account every type of material liquidity restrictions associated with the reporting fund?
A. 49.1:The instructions to Question 49 and Question 63 note that you should make a good faith determination of withdrawal/redemption provisions that would likely be triggered during conditions that you view as significant market stress.  Accordingly, when responding to these questions, you should only take into account discretionary restrictions that the adviser or fund governing body may impose on the reporting fund above any baseline liquidity restrictions an investor is already subject to in the ordinary course as terms of its investment in the fund.  For example, if a fund you manage generally imposes a 1-year initial lock-up period before an investor may make withdrawals/redemptions or only allows for annual withdrawals/redemptions upon 60 days’ notice, you should not take any of these restrictions into account when responding to Question 49 and Question 63 because these restrictions will be accounted for in responses to Question 50.  (Posted March 8, 2013)
 
Q. 49.2:Should I include assets subject to a side-pocket arrangement when responding to Questions 49(c) and 49(e) and Questions 63(b) and 63(d) regarding the reporting fund’s net asset value that may be subjected, or is subject, to material restrictions on investor withdrawals/redemptions?
A. 49.2:No.  You should, however, report the percentage of the reporting fund’s net asset value, if any, that is actually in a side-pocket  as of the data reporting date in Question 48(a).  (Posted March 8, 2013)
 

Question 50

Q. 50.1:Question 50 and Question 64 ask for the breakdown of the percentage of the reporting fund’s net asset value that is locked in for different periods of time.   When responding to these questions, should I take into account the investor liquidity associated with each different investor, such as different lock-up periods or side-letter terms associated with different investors?
A. 50.1:Yes.  You should evaluate the specific liquidity terms applicable to each investment as of the data reporting date, and then calculate the percentage of net asset value associated with each time period identified in the questions.  (Posted March 8, 2013)
 

Question 56

Q. 56.1:Question 56 requires large liquidity fund advisers to provide product exposures by maturity for certain listed asset classes. Unlike other instructions, the instructions to Question 56 do not appear to allow a filer to enter “NA” as a response, even if the liquidity fund does not have exposure to the listed asset class. How should a filer complete this Question if the liquidity fund does not have exposure to a listed asset class?
A. 56.1:In response to Question 56, a filer may enter “NA” as a response if the reporting liquidity fund does not have exposure to a listed asset class. (Posted June 29, 2012)
 

Question 57

See Question 35 above. (Posted March 8, 2013)
 

Question 63

See Question 49 above. (Posted March 8, 2013)
 

Question 64

See Question 50 above. (Posted March 8, 2013)
 

Question 76

Q. 76.1:Questions 76 and 77 reject certain NAICS codes I attempt to use.  What NAICS code should I use when this occurs?
A. 76.1: The list of NAICS codes available as valid responses on Form PF is a subset of the complete list of NAICS codes reported to the Internal Revenue Service.  When the PFRD system rejects or does not list the specific NAICS code most applicable to a particular portfolio company, Form PF filers should use the “parent” or more general level NAICS code.  For example, if a portfolio company has a specific NAICS code of 221113, you should categorize that portfolio company under the more general NAICS code of 221100.  Form PF web form filers can use the drop down menu imbedded within the online form to identify the correct NAICS code to use.  Form PF XML filers can view the list of acceptable NAICS codes within the Form PF Schema Documentation located at http://www.iard.com/pfrd/usersupport.asp (currently located on page 202 of the schema).  (Posted April 25, 2013)
 

Question 77

Q. 77.1:Question 77 asks for a breakdown of a reporting fund’s investments in portfolio companies by NAICS codes of the companies.  Should the breakdown be based on the percentage of the total gross value of the reporting fund’s investments in portfolio companies attributable to specific NAICS codes?
A. 77.1:Yes.  (Posted March 8, 2013)
 
Q. 77.2:See Question 76.1 above.  (Posted April 25, 2013)
 

Question 78

See Question 28 above. (Posted June 29, 2012)
 

Please send any further questions to FormPF@sec.gov.

A link to FINRA’s technical “Frequently Asked Questions” regarding the PFRD System can be found here: http://www.iard.com/pfrd/usersupport.asp.

 

http://www.sec.gov/divisions/investment/pfrd/pfrdfaq.shtml


Modified: 02/11/2014