Supporting Statement_Form PF_(2023)

OMB CONTROL Number: 3235-0679
SUPPORTING STATEMENT
For the Paperwork Reduction Act Information Collection Submission for
Form PF and Rule 204(b)-1
A. JUSTIFICATION
1.

Necessity for the Information Collection

Form PF [17 CFR 279.9] and rule 204(b)-1 [17 CFR 275.204(b)-1] under the Investment
Advisers Act of 1940 (“Advisers Act”) (together, the “rules”) require certain investment advisers
registered with the Securities and Exchange Commission (“SEC”) to report confidential
information about the private funds they advise. The rules implement provisions of Title IV of
the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), which
amended the Advisers Act to require the SEC to, among other things, establish reporting
requirements for advisers to private funds. 1 The information collected on Form PF is designed
to facilitate the Financial Stability Oversight Council’s (“FSOC”) monitoring of systemic risk in
the private fund industry and assist FSOC in determining whether and how to deploy its
regulatory tools with respect to nonbank financial companies. 2 The SEC and the Commodity
Futures Trading Commission (“CFTC”) also may use information collected on Form PF in their
regulatory programs, including examinations, investigations, and investor protection efforts
relating to private fund advisers. 3 Form PF is a joint form between the SEC and the CFTC with
respect to sections 1 and 2; the SEC solely adopted the other sections of the form. 4

1

See 15 U.S.C. 80b-4(b) and 15 U.S.C. 80b-11(e).

2

See Form PF.

3

Id.

4

See 15 U.S.C. 80b-11(e).

The rules contain a “collection of information” within the meaning of the Paperwork
Reduction Act of 1995 (“PRA”). 5 The title for the collection of information is “Form PF and
Rule 204(b)-1” (OMB Control Number 3235-0679), and includes both Form PF and rule 204(b)1. An agency may not conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB control number. Compliance
with the information collection is mandatory.
The respondents are investment advisers who are (1) registered or required to be
registered under Advisers Act section 203, (2) advise one or more private funds, and (3)
managed private fund assets of at least $150 million at the end of their most recently completed
fiscal year (collectively, with their related persons). 6 Form PF divides respondents into groups
based on their size and types of private funds they manage, requiring some groups to file more
information more frequently than others. The types of respondents are (1) smaller private fund
advisers, that report annually (i.e., private fund advisers that do not qualify as large private fund
advisers), (2) large hedge fund advisers, that report more information quarterly (i.e., advisers
with at least $1.5 billion in hedge fund assets under management), (3) large liquidity fund
advisers, that report more information quarterly (i.e., advisers that manage liquidity funds and
have at least $1 billion in combined money market and liquidity fund assets under management),
and (4) large private equity fund advisers, that report more information annually (i.e., advisers
with at least $2 billion in private equity fund assets under management).
In addition to periodic filings, advisers must file limited information on Form PF in five
situations. First, a large hedge fund adviser must file a current report as soon as practicable

5

44 U.S.C. 3501 through 3521.

6

See 17 CFR 275.204(b)-1.

upon, but no later than 72 hours after, the occurrence of certain reporting events. Second, a
private equity fund adviser must file an event report on a quarterly basis upon the occurrence of
certain reporting events. Third, any adviser that transitions from filing quarterly to annually
because it has ceased to qualify as a large hedge fund adviser or large liquidity fund adviser,
must file a Form PF indicating that it is no longer obligated to report on a quarterly basis.
Fourth, any adviser that is no longer subject to Form PF’s reporting requirements, must file a
final report indicating this. Fifth, an adviser may request a temporary hardship exemption if it
encounters unanticipated technical difficulties that prevent it from making a timely electronic
filing. A temporary hardship exemption extends the deadline for an electronic filing for seven
business days. To request a temporary hardship exemption, the adviser must file a request on
Form PF.
On May 3, 2023, the SEC adopted amendments to rule 204(b)-1 and the SEC-only
portions of Form PF. 7 The amendments are designed to enhance FSOC’s ability to monitor
systemic risk as well as bolster the SEC’s regulatory oversight of private fund advisers and
investor protection efforts. As discussed more fully in the adopting release, the amendments do
the following: 8
•

Require large hedge fund advisers to file current reports upon certain reporting
events;

•

Require private equity fund advisers to file event reports upon certain reporting
events; and

7

See Amendments to Form PF to Require Event Reporting for Large Hedge Fund Advisers and Private
Equity Fund Advisers and to Amend Reporting Requirements for Large Private Equity Fund Advisers,
Advisers Act Release No. 6297 (May 3, 2023) (“Amendments to Form PF”).

8

Id.

•

Amend how large private equity fund adviser report information about the private
equity funds they advise.

•

Under the amended rule, temporary hardship exemptions are available for current
reporting and event reporting.

2.

Purpose and Use of the Information Collection

The rules implement provisions of Title IV of the Dodd-Frank Act, which amended the
Advisers Act to require the SEC to, among other things, establish reporting requirements for
advisers to private funds. 9 The information collected on Form PF is designed to facilitate
FSOC’s monitoring of systemic risk in the private fund industry and assist FSOC in determining
whether and how to deploy its regulatory tools with respect to nonbank financial companies. 10
The SEC and the CFTC also may use information collected on Form PF in their regulatory
programs, including examinations, investigations, and investor protection efforts relating to
private fund advisers. 11 The amendments are designed to enhance FSOC’s ability to monitor
systemic risk as well as bolster the SEC’s regulatory oversight of private fund advisers and
investor protection efforts. 12
3.

Consideration Given to Information Technology

Advisers must file Form PF electronically with the Form PF filing system. 13 The
Financial Industry Regulatory Authority (“FINRA”) maintains the Form PF filing system
through the Private Fund Reporting Depository (“PFRD”), a subsystem of the Investment

9

See 15 U.S.C. 80b-4(b) and 15 U.S.C. 80b-11(e).

10

See Form PF.

11

Id.

12

See Amendments to Form PF, supra footnote 7.

13

See 17 CFR 275.204(b)-1(b).

Adviser Registration Depository (“IARD”), through which registered advisers are already
separately obligated to file annual reports on Form ADV [17 CFR 279.1]. Form PF may be filed
either through a fillable form on the PFRD website or through a batch filing process utilizing the
eXtensible Markup Language (“XML”) tagged data format. Certain advisers may prefer to
report in XML format because it allows them to automate aspects of their reporting and,
therefore, minimizes burdens and generates efficiencies for the adviser. Collecting information
electronically is designed to reduce the regulatory burden upon investment advisers by providing
a convenient portal for quickly transmitting reports and, for advisers that submit their reports in
XML format in particular, allowing them to automate aspects of their reporting.
4.

Duplication

The collection of information requirements of Form PF are not duplicated elsewhere.
5.

Effect on Small Entities

For the purposes of the Advisers Act and the Regulatory Flexibility Act of 1980, an
investment adviser generally is a small entity if it (1) has assets under management having a total
value of less than $25 million; (2) did not have total assets of $5 million or more on the last day
of the most recent fiscal year; and (3) does not control, is not controlled by, and is not under
common control with another investment adviser that has assets under management of $25
million or more, or any person (other than a natural person) that had total assets of $5 million or
more on the last day of its most recent fiscal year. 14
By definition, no small entity on its own, would meet rules’ minimum reporting threshold
of $150 million in regulatory assets under management attributable to private funds. Based on
Form PF and Form ADV data as of December 2022, the SEC estimates that no small entity

14

17 CFR 275.0-7.

advisers are required to file Form PF. The SEC does not have evidence to suggest that any small
entities are required to file Form PF but are not filing Form PF.
6.

Consequences of Not Conducting Collection

The rules implement provisions of Title IV of the Dodd-Frank Act, which amended the
Advisers Act to require the SEC to, among other things, establish reporting requirements for
advisers to private funds. 15 The information collected on Form PF is designed to facilitate
FSOC’s monitoring of systemic risk in the private fund industry and assist FSOC in determining
whether and how to deploy its regulatory tools with respect to nonbank financial companies. 16
The SEC and the CFTC also may use information collected on Form PF in their regulatory
programs, including examinations, investigations, and investor protection efforts relating to
private fund advisers. 17
The frequency of collection varies depending on the size of the adviser and the types of
private funds it manages, which balances the need for, and value of, current information against
the relative reporting burden for different types of advisers. If the information either is not
collected or is collected less frequently, FSOC’s ability to monitor systemic risk and deploy its
regulatory tools, as well as the SEC’s ability to protect investors, may be reduced.
7.

Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)

Under 5 CFR 1320.5(d)(2)(i), OMB will not approve a collection of information
requiring respondents to report information to the agency more often than quarterly,
unless the agency is able to demonstrate that it is necessary to satisfy statutory
requirements or other substantial need. The amendments require large hedge fund
15

See 15 U.S.C. 80b-4(b) and 15 U.S.C. 80b-11(e).

16

See Form PF.

17

Id.

advisers submit current reports as soon as practicable but no later than 72 hours from the
occurrence of reporting event, which could occur more or less than quarterly. The
current reporting requirements are necessary to satisfy statutory requirements or other
substantial need to assist the FSOC in its monitoring obligations under the Dodd-Frank
Act and assist the SEC in its investor protection efforts under the Advisers Act, by
providing the SEC and FSOC with more timely data to identify and respond to private
funds that are facing stress that could result in investor harm or systemic risk.
8.

Consultation Outside the Agency

The SEC and the staff of the Division of Investment Management participate in
an ongoing dialogue with representatives of the investment management industry
through public conferences, meetings, and informal exchanges. These various forums
provide the SEC and the staff with a means of ascertaining and acting upon paperwork
burdens confronting the industry. The SEC requested comment and considered
comments received on its proposal to amend the rules. 18
9.

Payment or Gift

Not applicable.
10.

Confidentiality

Responses to the information collection will be kept confidential to the extent permitted
by law. 19 Form PF elicits non-public information about private funds and their trading strategies,
the public disclosure of which could adversely affect the funds and their investors. The SEC

18

Amendments to Form PF to Require Current Reporting and Amend Reporting Requirements for Large
Private Equity Advisers and Large Liquidity Fund Advisers, Advisers Act Release No. 5950 (Jan. 26,
2022) [87 FR 9106 (Feb. 17, 2022)] (“2022 Form PF Proposing Release”).

19

See 5 CFR 1320.5(d)(2)(vii) and (viii).

does not intend to make public Form PF information that is identifiable to any particular adviser
or private fund, although the SEC may use Form PF information in an enforcement action and to
assess potential systemic risk. 20 SEC staff issues certain publications designed to inform the
public of the private funds industry, all of which use only aggregated or masked information to
avoid potentially disclosing any proprietary information. 21 The Advisers Act precludes the SEC
from being compelled to reveal Form PF information except (1) to Congress, upon an agreement
of confidentiality, (2) to comply with a request for information from any other Federal
department or agency or self-regulatory organization for purposes within the scope of its
jurisdiction, or (3) to comply with an order of a court of the United States in an action brought by
the United States or the SEC. 22 Any department, agency, or self-regulatory organization that
receives Form PF information must maintain its confidentiality consistent with the level of
confidentiality established for the SEC. 23 The Advisers Act requires the SEC to make Form PF
information available to FSOC. 24 For advisers that also are commodity pool operators or
commodity trading advisers, filing Form PF through the Form PF filing system is filing with
both the SEC and CFTC. 25 Therefore, the SEC makes Form PF information available to FSOC
and the CFTC, pursuant to Advisers Act section 204(b), making the information subject to the
confidentiality protections applicable to information required to be filed under that section.

20

See 15 U.S.C. 80b-10(c).

21

See, e.g., Private Funds Statistics, issued by staff of the SEC Division of Investment Management’s
Analytics Office, which we have used in this PRA as a data source, available at
https://www.sec.gov/divisions/investment/private-funds-statistics.shtml.

22

See 15 U.S.C. 80b-4(b)(8).

23

See 15 U.S.C. 80b-4(b)(9).

24

See 15 U.S.C. 80b-4(b)(7).

25

See Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and
Commodity Trading Advisors on Form PF, Advisers Act Release No. 3308 (Oct. 31, 2011), 76 FR 71128,
at n.17 (Nov. 16, 2011).

Before sharing any Form PF information, the SEC requires that any such department, agency, or
self-regulatory organization represent to the SEC that it has in place controls designed to ensure
the use and handling of Form PF information in a manner consistent with the protections
required by the Advisers Act. The SEC has instituted procedures to protect the confidentiality of
Form PF information in a manner consistent with the protections required in the Advisers Act. 26
11.

Sensitive Questions

Form PF elicits non-public information about private funds and their trading strategies,
the public disclosure of which could adversely affect the funds and their investors. A System of
Records Notice that covers the collection of information has been published in the Federal
Register at 83 FR 6892 and can also be found at
http://www.sec.gov/about/privacy/secprivacyoffice.htm. Instructions for obtaining the Privacy
Impact Assessment for IARD can be found at
http://www.sec.gov/about/privacy/secprivacyoffice.htm.
12.

Burden of Information Collection

We are revising our total burden estimates to reflect the adopted amendments, updated
data, and new methodology for certain estimates. 27 The tables below map out the Form PF
requirements as they apply to each group of respondents and detail our burden estimates.

26

See 5 CFR 1320.5(d)(2)(viii).

27

For the previously approved estimates, see ICR Reference No. 202209-3235-009 (conclusion date Nov. 3,
2022), available at https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202209-3235-009.

a.

Final Form PF Requirements by Respondent

Table 1: Final Form PF Requirements by Respondent
Smaller private
fund advisers

Large hedge
fund advisers

Large liquidity
fund advisers

Large private
equity fund
advisers

Annually

Quarterly

Quarterly

Annually

Annually, if they
advise hedge
funds

Quarterly

Quarterly, if
they advise
hedge funds

Annually, if they
advise hedge
funds

No

Quarterly

No

No

No

No

No

No

No

No

No

Annually

Section 5 (current reporting
concerning qualifying
hedge funds)
The adopted amendments
rules add section 5

No

No

No

Section 6 (event reporting
for private equity fund
advisers)
The adopted amendments
add section 6

Within 60 days
of fiscal quarter
end upon a
reporting event,
if they advise
private equity
funds

As soon as
practicable
upon a current
reporting event,
but no later
than 72 hours

No

No

Within 60 days of
fiscal quarter end
upon a reporting
event

Optional, if
they qualify

Optional, if they
qualify

Optional, if they
qualify

Form PF
Section 1a and section 1b
(basic information about
the adviser and the private
funds it advises)
No revisions
Section 1c (additional
information concerning
hedge funds)
No revisions
Section 2 (additional
information concerning
qualifying hedge funds)
No revisions
Section 3 (additional
information concerning
liquidity funds)
No revisions
Section 4 (additional
information concerning
private equity funds)
The adopted amendments
modify section 4

Section 7 (temporary
hardship request)
The adopted amendments
make this available for
current and private
equity event reporting

Optional, if they
qualify

b.

Annual Hour Burden Estimates

Below are tables with annual hour burden estimates for (1) initial filings, (2) ongoing
annual and quarterly filings, (3) current reporting and private equity event reporting, and (4)
transition filings, final filings, and temporary hardship requests.

Table 2: Annual Hour Burden Estimates for Initial Filings

Respondent

Number of
Respondents
=
Aggregate
Number of
Responses2

1

Smaller
Private
Fund
Advisers

Large
Liquidity
Fund
Advisers

Large
Private
Equity Fund
Advisers

Hours Per Response
Amortized Over 3
Years4

Aggregate
Hours
Amortized
Over 3 Years5

Proposed
Estimate 28

313 responses6

40 hours

÷ 3 =

13 hours

4,069 hours

Requested

358 responses7

40 hours

÷ 3 =

13 hours

4,654 hours

Previously
Approved

272 responses

40 hours

23 hours

6,256 hours

86 responses

0 hours

(10) hours

(1,602) hours

Proposed
Estimate

14 responses8

325 hours

÷ 3 =

108 hours

1,512 hours

Requested

16 responses9

325 hours

÷ 3 =

108 hours

1,728 hours

Previously
Approved

17 responses

325 hours

658 hours

11,186 hours

Change

(1) response

0 hours

(550) hours

(9,458) hours

Proposed
Estimate

1 response10

202 hours

÷ 3 =

67 hours

67 hours

Requested

1 response11

200 hours

÷ 3 =

67 hours

67 hours

Previously
Approved

2 responses

200 hours

588 hours

1,176 hours

Change

(1) response

0 hours

(521) hours

(1,109) hours

Proposed
Estimate

42 responses12

250 hours

÷ 3 =

83 hours

3,486 hours

Requested

17 responses13

252 hours14

÷ 3 =

84 hours

1,428 hours

Previously
Approved

9 responses

200 hours

133 hours

1,197 hours

Change

8 responses

52 hours

(49) hours

231 hours

Change

Large Hedge
Fund
Advisers

Hours Per
Response3

For all proposed estimates, see ICR Reference No. 202202-3235-026 (conclusion date May 17, 2022), available at
https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202202-3235-026.
28

Notes:
1.

We expect that the hourly burden will be most significant for the initial report because the adviser will need to
familiarize itself with the new reporting form and may need to configure its systems in order to efficiently gather
the required information. In addition, we expect that some large private fund advisers will find it efficient to
automate some portion of the reporting process, which will increase the burden of the initial filing but reduce the
burden of subsequent filings.
2. This concerns the initial filing; therefore, we estimate one response per respondent. The changes are due to using
updated data to estimate the number of advisers. The proposed changes concerning large private equity fund
advisers also were due to the proposed amendment to reduce the filing threshold, which will not be adopted in this
Release.
3. Hours per response changes for large private equity fund advisers are due to amendments to section 4. Hours per
response proposed estimate changes for large liquidity fund advisers were due to proposed amendments to section
3. We have reduced the final hours estimate from the proposed hours estimate because the proposed large liquidity
fund amendments will not be adopted in this Release.
4. We amortize the initial time burden over three years because we believe that most of the burden would be incurred
in the initial filing. We use a different methodology to calculate the estimate than the methodology staff used for
the previously approved burdens. We believe the previously approved burdens for initial filings inflated the
estimates by using a methodology that included subsequent filings for the next two years, which, for annual filers,
included 2 subsequent filings, and for quarterly filers, included 11 subsequent filings. For the requested burden, we
calculate the initial filing, as amortized over the next three years, by including only the hours related to the initial
filing, not any subsequent filings. This approach is designed to more accurately estimate the initial burden, as
amortized over three years. (For example, to estimate the previously approved burden for a large hedge fund
adviser making its initial filing, staff estimated that the adviser would have an amortized average annual burden of
658 hours (1 initial filing x 325 hours + 11 subsequent filings (because it files quarterly) x 150 hours = 1,975 hours.
1,975 hours / 3 years = approximately 658 previously approved hours per response, amortized over three years).)
Changes are due to using the revised methodology, and changes for the large hedge fund advisers also are due to
amendments to section 4. The proposed changes for large liquidity fund advisers were due to proposed
amendments to section 3, which we are not adopting in this Release.
5. (Number of responses) x (hours per response amortized over three years) = aggregate hours amortized over three
years. Changes are due to (1) using updated data to estimate the number of advisers and (2) the new methodology
to estimate the hours per response, amortized over three years. For large private equity fund advisers, changes in
our proposed estimates were also due to the proposed amendments to lower the threshold, which we are not
adopting in this Release, and amendments to section 4. The proposed changes for large liquidity fund advisers
were due to proposed amendments to section 3, which we are not adopting in this Release.
6. In the case of the proposed estimates, Private Funds Statistics show 2,427 smaller private fund advisers filed Form
PF in the fourth quarter of 2020. Based on filing data from 2016 through 2020, an average of 12.9 percent of them
did not file for the previous due date. (2,427 x 0.129 = 313 advisers.)
7. In the case of the requested values, Private Funds Statistics show 2,616 smaller private fund advisers filed Form PF
in the most recent reporting period. Based on filing data from 2017 through 2021, an average of 13.7 percent of
them did not file during the prior year. (2,616 x 0.137 = 358.39 advisers, rounded to 358 advisers.)
8. In the case of the proposed estimates, Private Funds Statistics show 545 large hedge fund advisers filed Form PF in
the fourth quarter of 2020. Based on filing data from 2016 through 2020, an average of 2.6 percent of them did not
file for the previous due date. (545 x 0.026 = 14.17 advisers, rounded to 14 advisers.)
9. In the case of the requested values, Private Funds Statistics show 598 large hedge fund advisers filed Form PF in
the most recent reporting period. Based on filing data from 2017 through 2021, an average of 2.7 percent of them
did not file during the prior year. (598 x 0.027 = 16.146 advisers, rounded to 16 advisers.)
10. In the case of the proposed estimates, Private Funds Statistics show 23 large liquidity fund advisers filed Form PF
in the fourth quarter of 2020. Based on filing data from 2016 through 2020, an average of 1.5 percent of them did
not file for the previous due date. (23 x 0.015 = 0.345 advisers, rounded up to 1 adviser.)
11. In the case of the requested values, Private Funds Statistics show 22 large liquidity fund advisers filed Form PF in
the most recent reporting period. Based on filing data from 2017 through 2021, an average of 1.5 percent of them
did not file during the prior year. (22 x 0.015= 0.33 advisers, rounded up to 1 adviser.)
12. In the case of the proposed estimates, Private Funds Statistics show 364 large private equity fund advisers filed
Form PF in the fourth quarter of 2020. Based on filing data from 2016 through 2020, an average of 3.5 percent of
them did not file for the previous due date. (364 x 0.035 = 12.74 advisers, rounded to 13 advisers.) As discussed in

section II.B of the 2022 Form PF Proposing Release, we estimated that reducing the filing threshold for large
private equity fund advisers would capture eight percent more of the U.S. private equity industry based on
committed capital (from 67 percent to 75 percent of the U.S. private equity industry). Therefore, we proposed to
estimate the number of large private equity fund advisers would increase by eight percent, as a result of the
proposed threshold. (364 large private equity fund advisers x 0.08 = 29.12, rounded to 29 additional large private
equity fund advisers filing for the first time as a result of the proposed threshold) + (13 advisers) = 42 advisers.)
13. In the case of the requested values, Private Funds Statistics show 435 large private equity fund advisers filed Form
PF in the most recent reporting period. Based on filing data from 2017 through 2021, an average of 3.9 percent of
them did not file during the prior year. (435 x 0.039 = 16.97 advisers, rounded to 17 advisers.) In a change from
the proposal, we are not adopting a change to the filing threshold for large private equity fund advisers in this
Release.
14. The increase in the hours estimate from the proposing estimate to the requested value is due to the change from a
current reporting requirement to an annual reporting requirement for large private equity fund advisers for general
partner and limited partner clawbacks, and in response to commenters. Our requested value considers that certain
proposed questions for large private equity fund advisers will be on an annual, rather than a current, basis.

Table 3: Annual Hour Burden Estimates for Ongoing Annual and Quarterly Filings
Number of
Respondents2

Respondent1

Smaller
Private
Fund
Advisers

2,114 advisers6

x

1 response

x

15 hours =

Requested

2,258 advisers7

x

1 response

x

15 hours =

Previously
Approved

2,055 advisers

x

1 response

x

15 hours =

0 responses

0 hours

31,710 hours
33,870 hours
30,825 hours
3,045 hours

531 advisers8

x

4 responses

x

150 hours =

Requested

582 advisers9

x

4 responses

x

150 hours =

Previously
Approved

537 advisers

x

4 responses

x

150 hours =

322,200 hours

0 hours

27,000 hours

45 advisers

0 responses

Proposed
Estimate

22 advisers10

x

4 responses

x

71 hours =

Requested

21 advisers11

x

4 responses

x

70 hours =

Previously
Approved

20 advisers

x

4 responses

x

70 hours =

Change
Large
Private
Equity
Fund
Advisers

203 advisers

Aggregate
Hours5

Proposed
Estimate

Change
Large
Liquidity
Fund
Advisers

Hours Per
Response4

Proposed
Estimate

Change

Large
Hedge
Fund
Advisers

Number of
Responses3

1 adviser

0 responses

0 hours

Proposed
Estimate

351 advisers12

x

1 response

x

Requested

418 advisers13

x

1 response

x 128 hours14 =

Previously
Approved

313 advisers

x

1 response

x

Change

105 advisers

0 responses

125 hours =

100 hours =
28 hours

318,600 hours
349,200 hours

6,248 hours
5,880 hours
5,600 hours
280 hours
43,875 hours
53,504 hours
31,300 hours
22,204 hours

Notes:
1.
2.
3.
4.

5.
6.

7.

8.

9.

10.

11.

12.

13.

14.

We estimate that after an adviser files its initial report, it will incur significantly lower costs to file ongoing annual
and quarterly reports, because much of the work for the initial report is non-recurring and likely created system
configuration and reporting efficiencies.
Changes to the number of respondents are due to using updated data to estimate the number of advisers. For large
private equity fund advisers, the changes in our proposed estimates were also due to the amendment to lower the
threshold, which we are not adopting in this Release.
Smaller private fund advisers and large private equity fund advisers file annually. Large hedge fund advisers and
large liquidity fund advisers file quarterly.
Hours per response changes for the large private equity fund advisers are due to the amendments to section 4.
Hours per response proposed estimate changes for large liquidity fund advisers were due to proposed amendments
to section 3. We have reduced the final hours estimate for large liquidity fund advisers from the proposed hours
estimate because the proposed large liquidity fund amendments will not be adopted in this Release.
Changes to the aggregate hours are due to using updated data to estimate the number of advisers. For large private
equity fund advisers, changes also are due to the amendments to section 4.
In the case of the proposed estimates, Private Funds Statistics show 2,427 smaller private fund advisers filed Form
PF in the fourth quarter of 2020. We estimated that 313 of them filed an initial filing, as discussed in Table 3:
Annual Hour Burden Estimates for Initial Filings. (2,427 total smaller advisers – 313 advisers who made an initial
filing = 2,114 advisers who make ongoing filings.)
In the case of the requested values, Private Funds Statistics show 2,616 smaller private fund advisers filed Form PF
in the most recent reporting period. We estimated that 358 of them filed an initial filing, as discussed in Table 3:
Annual Hour Burden Estimates for Initial Filings. (2,616 total smaller advisers – 358 advisers who made an initial
filing = 2,258 advisers who make ongoing filings.)
In the case of the proposed estimates, Private Funds Statistics show 545 large hedge fund advisers filed Form PF in
the fourth quarter of 2020. We estimated that 14 of them filed an initial filing, as discussed in Table 3: Annual
Hour Burden Estimates for Initial Filings. (545 total large hedge fund advisers – 14 advisers who made an initial
filing = 531 advisers who make ongoing filings.)
In the case of the requested values, Private Funds Statistics show 598 large hedge fund advisers filed Form PF in
the most recent reporting period. We estimated that 16 of them filed an initial filing, as discussed in Table 3:
Annual Hour Burden Estimates for Initial Filings. (598 total large hedge fund advisers – 16 advisers who made an
initial filing = 582 advisers who make ongoing filings.)
In the case of the proposed estimates, Private Funds Statistics show 23 large liquidity fund advisers filed Form PF
in the fourth quarter of 2020. We estimated that one of them filed an initial filing, as discussed in Table 3: Annual
Hour Burden Estimates for Initial Filings. (23 total large liquidity fund advisers – 1 adviser who made an initial
filing = 22 advisers who make ongoing filings.)
In the case of the requested values, Private Funds Statistics show 22 large liquidity fund advisers filed Form PF in
the most recent reporting period. We estimated that one of them filed an initial filing, as discussed in Table 3:
Annual Hour Burden Estimates for Initial Filings. (22 total large liquidity fund advisers – 1 adviser who made an
initial filing = 21 advisers who make ongoing filings.)
In the case of the proposed estimates, Private Funds Statistics show 364 large private equity fund advisers filed
Form PF in the fourth quarter of 2020. Based on filing data from 2016 through 2020, an average of 3.5 percent of
them did not file for the previous due date. (364 x 0.035 = 12.74 advisers, rounded to 13 advisers.) (364 total large
private equity fund advisers – 13 advisers who made an initial filing = 351 advisers who make ongoing filings.)
Lowering the filing threshold for large private equity fund advisers would result in additional advisers filing for the
first time, as discussed in Table 3: Annual Hour Burden Estimates for Initial Filings.
In the case of the requested values, Private Funds Statistics show 435 large private equity fund advisers filed Form
PF in the most recent reporting period. Based on filing data from 2017 through 2021, an average of 3.9 percent of
them did not file during the prior year. (435 x 0.039 = 16.97 advisers, rounded to 17 advisers.) (435 total large
private equity fund advisers – 17 advisers who made an initial filing = 418 advisers who make ongoing filings.) As
discussed in Table 3: Annual Hour Burden Estimates for Initial Filings, we are not adopting the proposed change in
threshold for large private equity fund advisers.
The increase in the hours estimate from the proposing estimate to the requested value is due to the change from a
current reporting requirement to an annual reporting requirement for large private equity fund advisers for general
partner and limited partner clawbacks and in response to commenters. Our requested value considers that certain
proposed questions for large private equity fund advisers will be on an annual, rather than a current, basis.

Table 4: Annual Hour Burden Estimates for Current Reporting and Private Equity
Event Reporting
Aggregate
Number of
Responses

Respondent1

Smaller
Private Fund
Advisers

Large Hedge
Fund
Advisers

Large Private
Equity Fund
Advisers

Hours Per
Response2

Aggregate
Hours

Proposed
Estimate

6 responses

x

8.5 hours

=

51 hours

Requested

20 responses

x

5 hours

=

100 hours

Previously
Approved

Not Applicable

Change

Not Applicable

Proposed
Estimate

6 responses

x

8.5 hours

=

51 hours

Requested

60 responses3

x

10 hours

=

600 hours

Previously
Approved

Not Applicable

Change

Not Applicable

Proposed
Estimate
Proposed
Estimate
Previously
Approved
Change

6 responses

x

8.5 hours

=

51 hours

20 responses

x

5 hours

=

100 hours

Not Applicable
Not Applicable

Notes:
1.

2.

In a change from the proposal, qualifying hedge fund advisers will file current reports under section 5
as soon as practicable, but no later than 72 hours from the current reporting event, and private equity
fund advisers will file event reports under section 6 on a quarterly basis, in each case rather than
within one business day as proposed. There are no previously approved estimates for the current
reporting and private equity event reporting amendments because they are new requirements.
We estimated in the proposal that the time to prepare and file a current report would range from 4
hours to 8.5 hours, depending on the current reporting event. Therefore, we proposed to use the upper
range (8.5 hours) to calculate estimates. In our requested values, we have revised the estimated time
to prepare and file a current report for large hedge fund advisers to 10 hours. We considered
comments that we received to our hour burden estimate, as well as changes to current reporting
questions and the reporting timeline from the proposed amendments to the final amendments. Our
final time burden estimate includes the costs associated with the required explanatory notes. We have
revised the estimated time to prepare and file a private equity event report for private equity fund
advisers to 5 hours in consideration of changes from the proposed amendments to the final
amendments to the event reporting questions and the change in the reporting timeline from within one
business day to on a quarterly basis.

3.

In light of comments received and modifications to the proposal, our estimate of the aggregate number
of responses expected across all current reporting and private equity event reporting categories has
increased. As discussed more fully in the adopting release, we have modified our estimate of the
number of current reports associated with extraordinary losses for large hedge fund advisers. We have
also modified our estimate of current reports and private equity reporting events associated with other
reporting event categories. We also recognize in our estimate that advisers may concurrently
experience multiple current reporting events or private equity reporting events, as applicable, and may
therefore report more than one reporting event in a single filing.

Table 5: Annual Hour Burden Estimates for Transition Filings, Final Filings, and
Temporary Hardship Requests
Filing Type1

Transition Filing
from Quarterly to
Annual

Final Filings

Temporary Hardship
Requests

Aggregate
Number of
Responses2

Hours Per
Response

Aggregate
Hours3

Proposed
Estimate

63 responses4

x

0.25 hours

=

15.75 hours

Requested

71 responses5

x

0.25 hours

=

17.75 hours

Previously
Approved

45 responses

x

0.25 hours

=

11.25 hours

Change

26 responses

0 hours

6.5 hours

Proposed
Estimate
Requested
Previously
Approved

232 responses6

x

0.25 hours

=

58 hours

235 responses7

x

0.25 hours

=

58.75 hours

54 responses

x

0.25 hours

=

13.5 hours

Change8

181 responses

Proposed
Estimate

3 responses9

x

1 hour

=

3 hours

Requested

4 responses10

x

1 hour

=

4 hours

Previously
Approved

4 responses

x

1 hour

=

4 hours

Change

0 responses

0 hours

0 hours

45.25 hours

0 hours

Notes:
1.

2.
3.
4.
5.

Advisers must file limited information on Form PF in three situations. First, any adviser that transitions
from filing quarterly to annually because it has ceased to qualify as a large hedge fund adviser or large
liquidity fund adviser, must file a Form PF indicating that it is no longer obligated to report on a
quarterly basis. Second, any adviser that is no longer subject to Form PF’s reporting requirements, must
file a final report indicating this. Third, an adviser may request a temporary hardship exemption if it
encounters unanticipated technical difficulties that prevent it from making a timely electronic filing. A
temporary hardship exemption extends the deadline for an electronic filing for seven business days. To
request a temporary hardship exemption, the adviser must file a request on Form PF. Under the final
rule, temporary hardship exemptions are available for current reporting and private equity event
reporting. This final amendment will not result in any changes to the hours per response.
Changes to the aggregate number of responses are due to using updated data. Changes for final filings
also are due to using a different methodology, as discussed below.
Changes to the aggregate hours are due to the changes in the aggregate number of responses.
In the case of the proposed estimates, Private Funds Statistics show 568 advisers filed quarterly reports
in the fourth quarter of 2020. Based on filing data from 2016 through 2020, an average of 11.1 percent
of them filed a transition filing. (568 x 0.111 = 63 responses.)
In the case of the requested values, Private Funds Statistics show 620 advisers filed quarterly reports in
the most recent reporting period. Based on filing data from 2017 through 2021, an average of 11.5
percent of them filed a transition filing. (620 x 0.115 = 71.3 responses, rounded to 71 responses.)

6.

In the case of the proposed estimates, Private Funds Statistics show 3,359 advisers filed Form PF in the
fourth quarter of 2020. Based on filing data from 2016 through 2020, an average of 6.9 percent of them
filed a final filing. (3,359 x 0.069 = approximately 232 responses.)
7. In the case of the requested values, Private Funds Statistics show 3,671 advisers filed Form PF in the
most recent reporting period. Based on filing data from 2017 through 2021, an average of 11.5 percent
of them filed a final filing. (3,671 x 0.115 = approximately 422 responses.)
8. Changes for final filings are due to using a different methodology. The previously approved estimates
used a percentage of quarterly filers to estimate how many advisers filed a final report. We use a
percentage of all filers to estimate how many advisers filed a final report, because all filers may file a
final report, not just quarterly filers. Therefore, this methodology is designed to more accurately
estimate the number of responses for final filings.
9. In the case of the proposed estimates, based on experience receiving temporary hardship requests, we
estimate that 1 out of 1,000 advisers will file a temporary hardship exemption annually. Private Funds
Statistics show there were 3,359 private fund advisers who filed Form PF in the fourth quarter of 2020.
(3,359 / 1,000 = approximately 3 responses.)
10. In the case of the requested values, Private Funds Statistics show there were 3,671 private fund advisers
who filed Form PF in the most recent reporting period. (3,671 / 1,000 = approximately 4 responses.)

c.

Annual Monetized Time Burden Estimates

Below are tables with annual monetized time burden estimates for (1) initial filings, (2)
ongoing annual and quarterly filings, (3) current reporting and private equity event reporting, and
(4) transition filings, final filings, and temporary hardship requests. 29

29

The hourly wage rates used in our estimates are based on (1) SIFMA’s Management & Professional
Earnings in the Securities Industry 2013, modified by SEC staff to account for an 1,800-hour work-year
and inflation, and multiplied by 5.35 to account for bonuses, firm size, employee benefits and overhead;
and (2) SIFMA’s Office Salaries in the Securities Industry 2013, modified by SEC staff to account for an
1,800-hour work-year and inflation, and multiplied by 2.93 to account for bonuses, firm size, employee
benefits and overhead. The requested values are based on the preceding SIFMA data sets, which SEC staff
have updated since the proposing release to account for current inflation rates.

Table 6: Annual Monetized Time Burden of Initial Filings
Per
Response2

Respondent1

Smaller
Private
Fund
Advisers

Large
Hedge
Fund
Advisers

Aggregate
Monetized
Time Burden
Amortized
Over 3 Years

$13,6205

÷ 3 =

$4,540 x

313 responses =

$1,421,020

Requested

$15,5206

÷ 3 =

$5,174 x

358 responses =

$1,852,292

x

272 responses =

$3,661,120

Previously
Approved
Change

$13,460
$2,060

86 responses

($1,808,828)

Proposed
Estimate

$104,4237

÷ 3 = $34,808 x

14 responses =

$487,312

Requested

$118,8908

÷ 3 = $39,630 x

16 responses =

$634,080

Previously
Approved

$103,123

x

17 responses =

$1,753,091

$15,767

(1) response

($1,119,011)

Proposed
Estimate

$64,8939

÷ 3 = $21,631 x

1 response =

$21,631

Requested

$73,20010

÷ 3 = $24,400 x

1 response =

$24,400

Previously
Approved

$63,460

x

2 responses =

$126,920

Change
Large
Private
Equity
Fund
Advisers

Aggregate
Number of
Responses4

Proposed
Estimate

Change
Large
Liquidity
Fund
Advisers

Per Response
Amortized
Over 3 years3

$9,740

(1) response

($102,520)

Proposed
Estimate

$80,32511

÷ 3 = $26,775 x

42 responses =

$1,124,550

Requested

$92,22112

÷ 3 = $30,740 x

17 responses =

$522,580

Previously
Approved

$63,460

x

9 responses =

$571,140

Change

$28,761

8 responses

($48,560)

Notes:
1.

2.
3.
4.
5.

6.

7.

8.

9.

We expect that the monetized time burden will be most significant for the initial report, for the same reasons
discussed in Table 3: Annual Hour Burden Estimates for Initial Filings. Accordingly, we anticipate that the
initial report will require more attention from senior personnel, including compliance managers and senior
risk management specialists, than will ongoing annual and quarterly filings. Changes are due to using (1)
updated hours per response estimates, as discussed in Table 3: Annual Hour Burden Estimates for Initial
Filings, (2) updated aggregate number of responses, as discussed in Table 3: Annual Hour Burden Estimates
for Initial Filings, and (3) updated wage estimates. Changes to the aggregate monetized time burden,
amortized over three years, also are due to amortizing the monetized time burden, which the previously
approved estimates did not calculate, as discussed below.
For the hours per response in each calculation, see Table 3: Annual Hour Burden Estimates for Initial Filings.
We amortize the monetized time burden for initial filings over three years, as we do with other initial burdens
in this PRA, because we believe that most of the burden would be incurred in the initial filing. The
previously approved burden estimates did not calculate this.
See Table 3: Annual Hour Burden Estimates for Initial Filings.
In the case of the proposed estimates, for smaller private fund advisers, we estimated that the initial report
would most likely be completed equally by a compliance manager at a cost of $316 per hour and a senior risk
management specialist at a cost of $365 per hour. Smaller private fund advisers generally would not realize
significant benefits from or incur significant costs for system configuration or automation because of the
limited scope of information required from smaller private fund advisers. (($316 per hour x 0.5) + ($365 per
hour x 0.5)) x 40 hours per response = $13,620.
In the case of the requested values, for smaller private fund advisers, we estimate that the initial report will
most likely be completed equally by a compliance manager at a cost of $360 per hour and a senior risk
management specialist at a cost of $416 per hour. Smaller private fund advisers generally would not realize
significant benefits from or incur significant costs for system configuration or automation because of the
limited scope of information required from smaller private fund advisers. (($416 per hour x 0.5) + ($360 per
hour x 0.5)) x 40 hours per response = $15,520.
In the case of the proposed estimates, for large hedge fund advisers, we estimated that for the initial report, of
a total estimated burden of 325 hours, approximately 195 hours will most likely be performed by compliance
professionals and 130 hours would most likely be performed by programmers working on system
configuration and reporting automation. Of the work performed by compliance professionals, we anticipate
that it will be performed equally by a compliance manager at a cost of $316 per hour and a senior risk
management specialist at a cost of $365 per hour. Of the work performed by programmers, we anticipated
that it would be performed equally by a senior programmer at a cost of $339 per hour and a programmer
analyst at a cost of $246 per hour. (($316 per hour x 0.5) + ($365 per hour x 0.5)) x 195 hours = $66,397.50.
(($339 per hour x 0.5) + ($246 per hour x 0.5)) x 130 hours = $38,025. $66,397.50 + $38,025 = $104,422.50,
rounded to $104,423.
In the case of the requested values, for large hedge fund advisers, we estimate that for the initial report, of a
total estimated burden of 325 hours, approximately 195 hours will most likely be performed by compliance
professionals and 130 hours will most likely be performed by programmers working on system configuration
and reporting automation. Of the work performed by compliance professionals, we anticipate that it will be
performed equally by a compliance manager at a cost of $360 per hour and a senior risk management
specialist at a cost of $416 per hour. Of the work performed by programmers, we anticipate that it will be
performed equally by a senior programmer at a cost of $386 per hour and a programmer analyst at a cost of
$280 per hour. (($360 per hour x 0.5) + ($416 per hour x 0.5)) x 195 hours = $75,600. (($386 per hour x
0.5) + ($280 per hour x 0.5)) x 130 hours = $43,290. $75,600 + $43,290 = $118,890.
In the case of the proposed estimates, for large liquidity fund advisers, we estimated that for the initial report,
of a total estimated burden of 202 hours, approximately 60 percent would most likely be performed by
compliance professionals and approximately 40 percent would most likely be performed by programmers
working on system configuration and reporting automation (that is approximately 121 hours for compliance
professionals and 81 hours for programmers). Of the work performed by compliance professionals, we
anticipated that it would be performed equally by a compliance manager at a cost of $316 per hour and a
senior risk management specialist at a cost of $365 per hour. Of the work performed by programmers, we
anticipated that it would be performed equally by a senior programmer at a cost of $339 per hour and a

programmer analyst at a cost of $246 per hour. (($316 per hour x 0.5) + ($365 per hour x 0.5)) x 121 hours =
$41,200.50. (($339 per hour x 0.5) + ($246 per hour x 0.5)) x 81 hours = $23,692.50. $41,200.50 +
$23,692.50 = $64,893.
10. In the case of the requested values, for large liquidity fund advisers, we estimate that for the initial report, of
a total estimated burden of 200 hours, approximately 60 percent will most likely be performed by compliance
professionals and approximately 40 percent will most likely be performed by programmers working on
system configuration and reporting automation (that is approximately 120 hours for compliance professionals
and 80 hours for programmers). Of the work performed by compliance professionals, we anticipate that it
will be performed equally by a compliance manager at a cost of $360 per hour and a senior risk management
specialist at a cost of $416 per hour. Of the work performed by programmers, we anticipate that it will be
performed equally by a senior programmer at a cost of $386 per hour and a programmer analyst at a cost of
$280 per hour. (($360 per hour x 0.5) + ($416 per hour x 0.5)) x 120 hours = $46,560. (($386 per hour x
0.5) + ($280 per hour x 0.5)) x 80 hours = $26,640. $46,560 + $26,640 = $73,200.
11. In the case of the proposed estimates, for large private equity fund advisers, we expected that for the initial
report, of a total estimated burden of 250 hours, approximately 60 percent would most likely be performed by
compliance professionals and approximately 40 percent would most likely be performed by programmers
working on system configuration and reporting automation (that is approximately 150 hours for compliance
professionals and 100 hours for programmers). Of the work performed by compliance professionals, we
anticipated that it would be performed equally by a compliance manager at a cost of $316 per hour and a
senior risk management specialist at a cost of $365 per hour. Of the work performed by programmers, we
anticipated that it would be performed equally by a senior programmer at a cost of $339 per hour and a
programmer analyst at a cost of $246 per hour. (($316 per hour x 0.5) + ($365 per hour x 0.5)) x 150 hours =
$51,075. (($339 per hour x 0.5) + ($246 per hour x 0.5)) x 100 hours = $29,250. $51,075 + $29,250 =
$80,325.
12. In the case of the requested values, for large private equity fund advisers, we expect that for the initial report,
of a total estimated burden of 252 hours, approximately 60 percent will most likely be performed by
compliance professionals and approximately 40 percent will most likely be performed by programmers
working on system configuration and reporting automation (that is approximately 151 hours for compliance
professionals and 101 hours for programmers). Of the work performed by compliance professionals, we
anticipate that it will be performed equally by a compliance manager at a cost of $360 per hour and a senior
risk management specialist at a cost of $416 per hour. Of the work performed by programmers, we anticipate
that it will be performed equally by a senior programmer at a cost of $386 per hour and a programmer analyst
at a cost of $280 per hour. (($360 per hour x 0.5) + ($416 per hour x 0.5)) x 151 hours = $58,588. (($386 per
hour x 0.5) + ($280 per hour x 0.5)) x 101 hours = $33,633. $58,588 + $33,633 = $92,221.

Table 7: Annual Monetized Time Burden of Ongoing Annual and Quarterly Filings
Respondent1

Smaller
Private Fund
Advisers

Large Hedge
Fund Advisers

Large
Liquidity
Fund Advisers

Large Private
Equity Fund
Advisers

Per Response2

Aggregate
Number of
Responses

Aggregate
Monetized
Time Burden

Proposed
Estimate

$4,2303 x

2,114 responses4 =

$8,942,220

Requested

$4,8155 x

2,258 responses6 =

$10,872,270

$4,173.75 x

2,055 responses =

$8,577,056

Previously
Approved
Change
Proposed
Estimate
Requested

Previously
Approved

$641.25

203 responses

$2,295,214

2,124 responses8 =

$89,845,200

$48,1509 x 2,328 responses10 =

$112,093,200

$42,3007 x

$41,737.50 x

2,148 responses =

$89,652,150

Change

$6,412.50

180 responses

Proposed
Estimate

$20,02211 x

88 responses12 =

$1,761,936

Requested

$22,47013 x

84 responses14 =

$1,887,480

Previously
Approved

$29,216.25 x

80 responses =

$2,337,300

Change9

($6,746.25)

$22,441,050

4 responses

($449,820)

Proposed
Estimate

$35,25015 x

351 responses16 =

$12,372,750

Requested

$41,73017 x

418 responses18 =

$17,443,140

Previously
Approved

$27,825 x

313 responses =

$8,709,225

Change

$13,905

105 responses

$8,733,915

Notes:
1.

2.

We expect that the monetized time burden will be less costly for ongoing annual and quarterly reports
than for initial reports, for the same reasons discussed in Table 4: Annual Hour Burden for Ongoing
Annual and Quarterly Filings. Accordingly, we anticipate that senior personnel will bear less of the
reporting burden than they would for the initial report. Changes are due to using (1) updated wage
estimates, (2) updated hours per response estimates, as discussed in Table 4: Annual Hour Burden for
Ongoing Annual and Quarterly Filings, and (3) updated aggregate number of responses. Changes to
estimates concerning large liquidity fund advisers primarily appear to be due to correcting a calculation
error, as discussed below.
For all types of respondents, in the case of the proposed estimates, we estimated that both annual and
quarterly reports would be completed equally by (1) a compliance manager at a cost of $316 per hour,
(2) a senior compliance examiner at a cost of $243, (3) a senior risk management specialist at a cost of

3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.

16.
17.

18.

$365 per hour, and (4) a risk management specialist at a cost of $203 an hour. ($316 x 0.25 = $79) +
($243 x 0.25 = $60.75) + ($365 x 0.25 = $91.25) + ($203 x 0.25 = $50.75) = $281.75, rounded to $282
per hour. For all types of respondents, in the case of the requested values, we estimate that both annual
and quarterly reports would be completed equally by (1) a compliance manager at a cost of $360 per
hour, (2) a senior compliance examiner at a cost of $276, (3) a senior risk management specialist at a
cost of $416 per hour, and (4) a risk management specialist at a cost of $232 an hour. ($360 x 0.25 =
$90) + ($276 x 0.25 = $69) + ($416 x 0.25 = $104) + ($232 x 0.25 = $58) = $321. To calculate the cost
per response for each respondent, we used the hours per response from Table 4: Annual Hour Burden for
Ongoing Annual and Quarterly Filingss.
In the case of the proposed estimates, cost per response for smaller private fund advisers: ($282 per hour
x 15 hours per response = $4,230 per response.)
In the case of the proposed estimates, (2,114 smaller private fund advisers x 1 response annually = 2,114
aggregate responses.)
In the case of the requested values, cost per response for smaller private fund advisers: ($303 per hour x
15 hours per response = $4,545 per response.)
In the case of the requested values, (2,258 smaller private fund advisers x 1 response annually = 2,258
aggregate responses.)
In the case of the proposed estimates, cost per response for large hedge fund advisers: ($282 per hour x
150 hours per response = $42,300 per response.)
In the case of the proposed estimates, (531 large hedge fund advisers x 4 response annually = 2,124
aggregate responses.)
In the case of the requested values, cost per response for large hedge fund advisers: ($321 per hour x 150
hours per response = $48,150 per response.)
In the case of the requested values, (582 large hedge fund advisers x 4 responses annually = 2,328
aggregate responses.)
In the case of the proposed estimates, cost per response for large liquidity fund advisers: ($282 per hour
x 71 hours per response = $20,022 per response.
In the case of the proposed estimates, (22 large liquidity fund advisers x 4 responses annually = 88
aggregate responses.)
In the case of the requested values, cost per response for large liquidity fund advisers: ($321 per hour x
70 hours per response = $22,470 per response.
In the case of the requested values, (21 large liquidity fund advisers x 4 responses annually = 84
aggregate responses.)
The previously approved estimates appear to have mistakenly used a different amount of hours per
response (105 hours), rather than the actual estimate for large liquidity fund advisers (which was 70
hours per response), causing the monetized time burden to be inflated in error. Therefore, the extent of
these changes are primarily due to using the correct hours per response, which we now estimate as 70
hours, as discussed in Table 4: Annual Hour Burden for Ongoing Annual and Quarterly Filings. In the
case of the proposed estimates, cost per response for large private equity fund advisers: ($282 per hour x
125 hours per response = $35,250 per response.)
In the case of the proposed estimates, (351 large private equity fund advisers x 1 response annually = 351
aggregate responses.)
In the case of the requested values, cost per response for large private equity fund advisers: ($321 per
hour x 130 hours per response = $41,730 per response.)
In the case of the requested values, (418 large private equity fund advisers x 1 response annually = 418
aggregate responses.)

Table 8: Annual Monetized Time Burden of Current Reporting and Private
Equity Event Reporting
Respondent1

Smaller Private
Fund Advisers

Large Hedge Fund
Advisers

Large Private
Equity Fund
Advisers

Per Response

Aggregate
Number of
Responses2

Aggregate
Monetized
Time Burden

Proposed
Estimate

$4,1823 x

6 responses =

$25,902

Requested

$2,0244 x 20 responses =

$40,480

Previously
Approved
Change
Proposed
Estimate
Requested

Not Applicable
Not Applicable
$3,5385 x

6 responses =

$21,228

$5,1606 x 60 responses =

$309,600

Previously
Approved

Not Applicable

Change

Not Applicable

Proposed
Estimate

$4,1823 x

6 responses =

$25,092

Requested

$2,0244 x 20 responses =

$40,480

Previously
Approved

Not Applicable

Change

Not Applicable

Notes:
1.

2.
3.

4.

In a change from the proposal, qualifying hedge fund advisers will file current reports under
section 5 as soon as practicable, but no later than 72 hours from the current reporting event,
and private equity fund advisers will file event reports under section 6 on a quarterly basis, in
each case rather than within one business day as proposed. There are no previously approved
estimates for these final amendments because they are new requirements.
See Table 5: Annual Hour Burden Estimates for Current Reporting and Private Equity Event
Reporting.
In the case of the proposed estimates, for the cost per response for smaller private fund
advisers and large private equity fund advisers, we estimated that, depending on the
circumstances, different legal professionals at the adviser would work on the current report or
the private equity event report, as applicable. We estimated that the time costs for a legal
professional to be approximately $492, which is a blended average of hourly rate for a deputy
general counsel ($610) and compliance attorney ($373). (8.5 hours to file current report or
private equity event report, as applicable x $492 per hour for a legal professional = $4,182).
In the case of the requested values, we estimate that the time costs for a legal professional to
be approximately $560, which is a blended average of hourly rate for a deputy general counsel
($695) and compliance attorney ($425). We estimate that the time costs for a financial
professional to be approximately $355, which is a blended average hourly rate for a senior risk
management specialist ($416) and a financial reporting manager ($339). Of the total 5 hours
that a private equity event report would take, we estimate that an adviser would spend on
average 2.5 hours of legal professional time and 1.5 hours of financial professional time to

5.

6.

prepare, review, and submit a private equity event report. (2.5 hours x $560 per hour for a
legal professional = $1,400) + (1.5 hours x $416 per hour for a financial professional = $624)
= $2,024.
In the case of the proposed estimates, for the cost per response, we estimated that, depending
on the circumstances, different legal professionals and financial professionals at the advisers
would work on the current report because the current reporting events may require both legal
and quantitative analysis. We estimated that the time costs for a legal professional to be
approximately $492, which is a blended average of hourly rate for a deputy general counsel
($610) and compliance attorney ($373). We estimate that the time costs for a financial
professional to be approximately $331, which is a blended average hourly rate for a senior risk
management specialist ($365) and a financial reporting manager ($297). Of the total 8.5 hours
that a current report would take, we estimate that an adviser would spend on average 4.5 hours
of legal professional time and 4 hours of financial professional time to prepare, review, and
submit a current report pursuant to section 5. (4.5 hours x $492 per hour for a legal
professional = $2,214) + (4 hours x $331 per hour for a financial professional = $1,324) =
$3,583.
In the case of the requested values, we estimate that the time costs for a legal professional to
be approximately $560, which is a blended average of hourly rate for a deputy general counsel
($695) and compliance attorney ($425). We estimate that the time costs for a financial
professional to be approximately $355, which is a blended average hourly rate for a senior risk
management specialist ($416) and a financial reporting manager ($339). Of the total 10 hours
that a current report would take, we estimate that an adviser would spend on average 5.5 hours
of legal professional time and 4.5 hours of financial professional time to prepare, review, and
submit a current report. (5.5 hours x $560 per hour for a legal professional = $3,080) + (5
hours x $416 per hour for a financial professional = $2,080) = $5,160.

Table 9: Annual Monetized Time Burden for Transition Filings, Final Filings, and
Temporary Hardship Requests
Per
Response

Filing Type1
Proposed
Estimate
Transition Filing from
Quarterly to Annual

63 responses =

$1,134

Requested

$20.504 x

71 responses =

$1,455.50

Previously
Approved

$17.75 x

45 responses =

$621.25

26 responses

$834.25

Proposed
Estimate

Temporary Hardship
Requests

Aggregate
Monetized
Time Burden

$183 x

Change

Final Filings

Aggregate
Number of
Responses2

$2.75
$185 x

232 responses =

$4,176

Requested

20.506 x

422 responses =

$8,651

Previously
Approved

$17.75 x

54 responses =

$958.50

Change

$2.75

Proposed
Estimate

$2227 x

3 responses =

$666

Requested

$252.388 x

4 responses =

$1,009.52

Previously
Approved

$221.63 x

4 responses =

$886.52

Change

$30.75

368 responses

0 responses

$7,692.50

$123

Notes:
1.
2.

All changes are due to using updated data concerning wage rates and the number of responses.
See Table 6: Annual Hour Burden Estimates for Transition Filings, Final Filings, and Temporary
Hardship Requests.
3. In the case of the proposed estimates, we estimated that each transition filing would take 0.25 hours and
that a compliance clerk would perform this work at a cost of $72 an hour. (0.25 hours x $72 = $18.)
4. In the case of the requested values, we estimate that each transition filing will take 0.25 hours and that a
compliance clerk would perform this work at a cost of $82 an hour. (0.25 hours x $82 = $20.50.)
5. In the case of the proposed estimates, we estimated that each transition filing would take 0.25 hours and
that a compliance clerk would perform this work at a cost of $72 an hour. (0.25 hours x $72 = $18.)
6. In the case of the requested values, we estimate that each transition filing will take 0.25 hours and that a
compliance clerk would perform this work at a cost of $82 an hour. (0.25 hours x $82 = $20.50.)
7. In the case of the proposed estimates, we estimated that each temporary hardship request will take 1
hour. We estimated that a compliance manager would perform five-eighths of the work at a cost of
$316 and a general clerk would perform three-eighths of the work at a cost of $64. (1 hour x ((5/8 of an
hour x $316 = $197.50) + (3/8 of an hour x $64 = $24)) = $238 per response.
8. In the case of the requested values, we estimate that each temporary hardship request will take 1 hour.
We estimate that a compliance manager would perform five-eighths of the work at a cost of $360 and a
general clerk would perform three-eighths of the work at a cost of $73. (1 hour x ((5/8 of an hour x
$360 = $225) + (3/8 of an hour x $73 = $27.38)) = $252.38 per response.

13.

Cost to Respondents

We estimate an aggregate annual estimated external cost burden of $1,610,828, which
represents a decrease of $2,018,022 from the previously approved estimate of $3,628,850. See
Table 13: Aggregate Annual Estimates, below, which summarizes the total aggregated annual
estimated external cost burden. Also see the tables below, which detail the annual external cost
burden estimates for (1) initial filings as well as ongoing annual and quarterly filings and (2)
current and event reporting. There are no filing fees for transition filings, final filings, or

temporary hardship requests and we continue to estimate there would be no external costs for
those filings, as previously approved.

Table 10: Annual External Cost Burden for Ongoing Annual and Quarterly Filings as well as Initial
Filings

Respondent1

Smaller
Private
Fund
Advisers

Large
Hedge
Fund
Advisers

Number of
Responses Per
Respondent2

External
Cost of
Initial
Filing4

External Cost
of Initial
Number
Filing
of Initial
Amortized
Filings6
Over 3
Years5

Total
Aggregate
External
Cost8

Proposed
Estimate

1 x $150 =

$150

Not Applicable

$364,0509

Requested

1 x $150 =

$150

Not Applicable

$392,40010

Previously
Approved

1 x $150 =

$150

Not Applicable

$349,050

Change

0

No Change

$43,350

Proposed
Estimate

4 x $150 =

$600

$50,000

÷ 3 = $16,667 x 14 =

$233,338

$560,33811

Requested

4 x $150 =

$600

$50,000

÷ 3 = $16,667 x 16 =

$266,672

$625,47212

Previously
Approved

4 x $150 =

$600

$50,000

x 17 =

$850,000

$1,182,400

Change

0

$0

$0

($583,328)

($556,928)

Proposed
Estimate

4 x $150 =

$600

$50,000

÷ 3 = $16,667 x

1 =

$16,667

$30,46713

4 x $150 =

$600

$50,000

÷ 3 = $16,667 x

1 =

$16,667

$29,86714

4 x $150 =

$600

$50,000

x

2 =

$100,000

$113,200

$0

$0

($83,333)

($83,333)

Large
Liquidity Requested
Previously
Fund
Advisers Approved

Large
Private
Equity
Fund
Advisers

Filing
Total
Fee
Filing
Per
Fees
Filing3

Aggregate
External
Cost of
Initial
Filing
Amortized
Over 3
Years7

$0

$0

$0

(1)

Change

0

Proposed
Estimate

1 x $150 =

$150

$50,000

÷ 3 = $16,667 x 42 =

$700,014

$754,61415

Requested

1 x $150 =

$150

$50,000

÷ 3 = $16,667 x 17 =

$283,339

$348,58916

Previously
Approved

1 x $150 =

$150

$50,000

$450,000

$498,300

Change

0

$0

$0

($166,661)

($149,711)

$0

$0

(1)

x

9 =
8

Notes:
1.
2.
3.
4.

5.
6.
7.

8.

9.
10.
11.
12.
13.
14.
15.
16.

We estimate that advisers would incur the cost of filing fees for each filing. For initial filings, advisers may incur costs to modify
existing systems or deploy new systems to support Form PF reporting, acquire or use hardware to perform computations, or
otherwise process data required on Form PF.
Smaller private fund advisers and large private equity fund advisers file annually. Large hedge fund advisers and large liquidity
fund advisers file quarterly.
The SEC established Form PF filing fees in a separate order. Since 2011, filing fees have been and continue to be $150 per annual
filing and $150 per quarterly filing. See Order Approving Filing Fees for Exempt Reporting Advisers and Private Fund Advisers,
Advisers Act Release No. 3305 (Oct. 24, 2011) [76 FR 67004 (Oct. 28, 2011)].
In the previous PRA submission for the rules, staff estimated that the external cost burden for initial filings would range from $0 to
$50,000 per adviser. This range reflected the fact that the cost to any adviser may depend on how many funds or the types of funds
it manages, the state of its existing systems, the complexity of its business, the frequency of Form PF filings, the deadlines for
completion, and the amount of information the adviser must disclose on Form PF. Smaller private fund advisers would be unlikely
to bear such costs because the information they must provide is limited and will, in many cases, already be maintained in the
ordinary course of business. We continue to estimate that the same cost range would apply.
We amortize the external cost burden of initial filings over three years, as we do with other initial burdens in this PRA, because we
believe that most of the burden would be incurred in the initial filing. The previously approved burden estimates did not calculate
this.
See Table 3: Annual Hour Burden Estimates for Initial Filings.
Changes to the aggregate external cost of initial filings, amortized over three years are due to (1) using updated data and (2)
amortizing the external cost of initial filings over three years, which the previously approved PRA did not calculate. Changes
concerning large private equity fund advisers in our proposed estimates were also due to the proposed amendment to reduce the
filing threshold, which we are not adopting in this Release.
Changes to the total aggregate external cost are due to (1) using updated data and (2) amortizing the external cost of initial filings
over three years, which the previously approved PRA did not calculate. Changes concerning large private equity fund advisers in
our proposed estimates were also due to the proposed amendment to reduce the filing threshold, which we are not adopting in this
Release.
In the case of the proposed estimates, Private Funds Statistics show 2,427 smaller private fund advisers filed Form PF in the fourth
quarter of 2020. (2,427 smaller private fund advisers x $150 total filing fees) = $364,050 aggregate cost.
In the case of the requested values, Private Funds Statistics show 2,616 smaller private fund advisers filed Form PF in the most
recent reporting period. (2,616 smaller private fund advisers x $150 total filing fees) = $392,400 aggregate cost.
In the case of the proposed estimates, Private Funds Statistics show 545 large hedge fund advisers filed Form PF in the fourth
quarter of 2020. (545 large hedge fund advisers x $600 total filing fees) + $233,338 total external costs of initial filings, amortized
over three years = $560,338 aggregate cost.
In the case of the requested values, Private Funds Statistics show 598 large hedge fund advisers filed Form PF in the most recent
reporting period. (598 large hedge fund advisers x $600 total filing fees) + $266,672 total external costs of initial filings,
amortized over three years = $625,472 aggregate cost.
In the case of the proposed estimates, Private Funds Statistics show 23 large liquidity fund advisers filed Form PF in the fourth
quarter of 2020. (23 large liquidity fund advisers x $600 total filing fees) + $16,667 total external costs of initial filings, amortized
over three years = $30,467 aggregate cost.
In the case of the requested values, Private Funds Statistics show 22 large liquidity fund advisers filed Form PF in the most recent
reporting period. (22 large liquidity fund advisers x $600 total filing fees) + $16,667 total external costs of initial filings,
amortized over three years = $29,867 aggregate cost.
In the case of the proposed estimates, Private Funds Statistics show 364 large private equity fund advisers filed Form PF in the
fourth quarter of 2020. (364 large private equity fund advisers x $150 total filing fees) + $700,014 total external costs of initial
filings, amortized over three years = $754,614 aggregate cost.
In the case of the requested values, Private Funds Statistics show 435 large private equity fund advisers filed Form PF in the most
recent reporting period. (435 large private equity fund advisers x $150 total filing fees) + $283,339 total external costs of initial
filings, amortized over three years = $348,589 aggregate cost.

Table 11: Annual External Cost Burden for Current Reporting and Private Equity Event
Reporting
Cost of Outside
Counsel Per
Aggregate
Current
Report
Number of
Respondent1
or
Private
Responses2
Equity Event
Report
Proposed
6
x
$9925
Estimate
Smaller
Requested
20
x $1,6956
Private
Fund
Previously
Advisers
Approved

Aggregate
Cost of
Outside
Counsel

Large
Private
Equity
Fund
Advisers

Total
Aggregate
External
Cost4

=

$5,952

$12,500

$18,452

=

$33,900

$15,000

$48,900

Not Applicable

Change
Large
Hedge
Fund
Advisers

One-time Cost
of System
Changes3

Not Applicable

Proposed
Estimate

6

Requested

60

x

$9925

=

$5,952

$12,500

$18,452

x $1,6956

=

$101,700

$15,000

$116,700

Previously
Approved

Not Applicable

Change

Not Applicable

Proposed
Estimate

6

Requested

20

x

$9925

=

$5,952

$12,500

$18,452

x $1,6956

=

$33,900

$15,000

$48,900

Previously
Approved

Not Applicable

Change

Not Applicable

Advisers would pay filing fees, the amount of which would be determined in a separate action.

Notes:
1. In a separate action, the SEC would approve filing fees that reflect the reasonable costs associated with
current report and private equity event report filings and the establishment and maintenance of the filing
system. (See 15 U.S.C. 80b-4(c).) We estimate that large hedge fund advisers and private equity fund
advisers would incur costs of outside counsel for each current report or private equity event report, as
applicable. We also estimate that large hedge fund advisers and private equity fund advisers may incur a
one-time cost to modify existing systems or deploy new systems to support current reporting or private equity
event reporting, as applicable,, acquire or use hardware to perform computations, or otherwise process data to
identify the reporting events set forth in section 5 or section 6, as applicable, because such reporting events
are quantitative. There are no previously approved estimates for the current reporting amendment or private
equity event report amendment because they are new requirements.
2. See Table 5: Annual Hour Burden Estimates for Current Reporting and Private Equity Event Reporting.
3. In the case of the proposed estimates, we estimated that the one-time external cost burden would range
from $0 to $12,500, per adviser. This range of costs reflects the fact that the cost to any adviser might
depend on how many funds or the types of funds it manages, the state of its existing systems, and the
complexity of its business. In consideration of comments, we have increased our estimate of the one-time
external cost burden to between $0 and $15,000, per adviser. Our cost estimate also considers the
compliance date for current and private equity event reporting.
4. (Aggregate cost of outside counsel) + (one-time cost of system changes, as applicable) = total aggregate
cost.
5. In the case of the proposed estimates, we estimated the cost for outside legal counsel is $496. This is
based on an estimated $400 per hour cost for outside legal services, as used by the Commission for these
services in the “Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers With Less Than
$150 Million Under Management, and Foreign Private Advisers” final rule, Advisers Act Release No. 3222
(June 22, 2011) [76 FR 39646 (July 6, 2011)], as inflated using the Consumer Price Index. We estimated that
approximately two hours of the total legal professional time that would otherwise be spent on current
reporting, would be shifted from in-house legal professionals to outside legal counsel. (2 hours x $496 for
outside legal services = $992.)
6. In the case of the requested values, we estimate the cost for outside legal counsel is $565. We estimate
that approximately three hours of the total legal professional time that would otherwise be spent on current
reporting or private equity event reporting, would be shifted from in-house legal professionals to outside legal
counsel. The increased hour estimate reflects our increased hour burden for current reporting and private
equity event reporting. (3 hours x $565 for outside legal services = $1,695.)

14.

Cost to the Federal Government

There are no costs to the government directly attributable to Form PF.
15.

Change in Burden

The aggregate annual estimate of 3,671 respondents represents an increase of 446
respondents from the previously approved estimate of 3,225 respondents. The aggregate annual
estimate of 5,907 responses represents an increase of 851 responses from the previously
approved estimate of 5,056 responses. The aggregate annual estimated time burden of 451,012
hours represents an increase of 41,244 hours from the previously approved estimate of 409,768

hours. The aggregate annual estimated monetized time burden of $145,721,172.52 represents a
decrease of $23,569,072.27from the previously approved estimate of $122,152,100.25. The
aggregate annual estimated external cost burden of $1,610,828 represents a decrease of
$2,018,022 from the previously approved estimate of $3,628,850. The changes are due to the
amendments, updated data, and using a new methodology for certain estimates.
16.

Information Collection Planned for Statistical Purposes

Not applicable.
17.

Approval to Omit OMB Expiration Date

We request authorization to omit the expiration date on the electronic version of Form
PF, although the OMB control number will be displayed. Including the expiration date on the
electronic version of this form will result in increased costs, because the need to make changes to
the form may not follow the application’s scheduled version release dates.
18.

Exceptions to Certification Statement for Paperwork Reduction Act
Submission

Not applicable.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

Not applicable.