Supporting Statement A

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PAPERWORK REDUCTION ACT SUPPORTING STATEMENT

for the Proposal of
Form PF and Rule 204(b)-1
OMB Control Number 3235-0679
The U.S. Securities and Exchange Commission (“Commission” or SEC) submits this
information collection request (ICR) pursuant to the Paperwork Reduction Act of 1995 (PRA), 44
U.S.C. Section 3501 et seq., with the following justification.

1.

Necessity of 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.
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. 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. 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.
The rules contain a “collection of information” within the meaning of the Paperwork Reduction
Act of 1995 (“PRA”). 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). 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).
U.S. Securities and Exchange Commission (SEC)
Page 1 of 24

On April 20, 2026, the SEC and CFTC proposed amendments to rule 204(b)-1 and the SEC-only
portions of Form PF. The amendments are designed to eliminate certain filing and reporting
obligations, streamline certain requirements, and make corrections and other revisions. As discussed
more fully in the proposing release, the proposed amendments do the following:
•
Raise the Form PF filing threshold for all filers, from $150 million in private fund assets
under management to $1 billion;
•
Raise the reporting threshold for large hedge fund advisers from $1.5 billion in hedge
fund assets under management to $10 billion; and
•
Streamline many Form PF requirements, including, but not limited to, by: eliminating
certain “look through” requirements; eliminating certain performance volatility reporting requirements;
simplifying certain large hedge fund counterparty exposure reporting; eliminating certain current
reporting for large hedge fund advisers; eliminating quarterly event reporting for all private equity fund
advisers; and making corrections and other revisions.

2.

Purpose and Use of 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. 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. 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. The amendments are designed to
eliminate certain burdens, among other things, while ensuring Form PF continues to collect information
necessary and appropriate in the public interest and for the protection of investors, or for the assessment
of systemic risk in the U.S. financial system by FSOC.

3.

Use and Consideration of Information Technology

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

Identifying and Minimizing Duplication
The collection of information requirements of Form PF are not duplicated elsewhere.

U.S. Securities and Exchange Commission (SEC)
Page 2 of 24

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.
By definition, no small entity on its own would meet the rule’s minimum reporting
threshold of $150 million in regulatory assets under management, nor the proposed minimum filing
threshold of $1 billion in private fund assets under management. Based on Form PF and Form ADV
data as of the first quarter of 2025, the SEC estimates that no small entity advisers are required to file
Form PF, and no small entity advisers would be required to file Form PF under the proposed
amendments. 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 and Obstacles to Reducing
Burden

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. 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. 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.
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. Form PF
requires certain large hedge fund advisers to submit current reports, which could occur more or less than
quarterly. The current reporting requirements are necessary to satisfy statutory requirements or other
substantial need to assist 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.

Public Comment and Consultations Outside the Agency
The SEC did not receive public comment during the 60-day notice and comment period.

U.S. Securities and Exchange Commission (SEC)
Page 3 of 24

9.

Payment or Gift to Respondents
Not applicable.

10.

Assurance of Confidentiality and Privacy

Responses to the information collection will be kept confidential to the extent permitted by law.
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 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.
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. 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. 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. The Advisers Act requires the SEC to make Form PF
information available to FSOC. 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. 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. 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.

11.

Collection Questions of a Sensitive Nature
Not applicable.

12.

Estimated Time Burden and its Cost Equivalent
We are revising our total burden estimates to reflect the proposed amendments, updated data, and

new methodology for certain estimates. 1 The tables below map out the Form PF requirements as they
apply to each group of respondents and detail our burden estimates.

1

For the previously approved estimates, see ICR Reference No. 202405-3235-009 (conclusion date July 2, 2024),
available at https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202405-3235-009.

U.S. Securities and Exchange Commission (SEC)
Page 4 of 24

a.

Proposed Form PF Requirements by Respondent

PRA Table 1: Proposed Form PF Requirements by Respondent
Smaller
Large private
Large hedge
Large liquidity
Form PF
private fund
equity fund
fund advisers
fund advisers
advisers1
advisers
Section 1a and section 1b
(basic information about
Annually
Quarterly
Quarterly
Annually
the adviser and the private
funds it advises)
Proposed revisions
Section 1c (additional
Annually, if
Quarterly, if
information concerning
Annually, if they
they advise
Quarterly
they advise
hedge funds)
advise hedge funds
hedge funds
hedge funds
Proposed revisions
Section 2 (additional
information concerning
No
Quarterly
No
No
qualifying hedge funds)
Proposed revisions
Section 3 (additional
information concerning
liquidity funds)
No
No
Quarterly
No
No proposed substantive
revisions
Section 4 (additional
information concerning
No
No
No
Annually
private equity funds)
No proposed substantive
revisions
Section 5 (current
reporting concerning
No later than
No
No
No
qualifying hedge funds)
72 hours
Proposed revisions
Section 6 (event reporting
for private equity fund
N/A
N/A
N/A
N/A
advisers)
Proposed deletion
Section 7 (temporary
Optional, if
Optional, if
Optional, if they
Optional, if they
hardship request)
they
qualify
they
qualify
qualify
qualify
No proposed revisions
Transition Filings
If they cease to If they cease to
(indicating the adviser is
qualify as a
qualify as a
Not applicable
no longer obligated to file Not applicable
large hedge
large liquidity
on a quarterly basis)
fund adviser
fund adviser
No proposed revisions
Final Filings (indicating
the adviser is no longer
If they qualify If they qualify
If they qualify
If they qualify
subject to the rules)
No proposed revisions
Notes:
1. Smaller private fund advisers are considered all other advisers required to file Form PF that do not meet the
definition of large hedge fund adviser, large liquidity fund adviser, or large private equity fund adviser.

U.S. Securities and Exchange Commission (SEC)
Page 5 of 24

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.

U.S. Securities and Exchange Commission (SEC)
Page 6 of 24

PRA Table 2: Annual Hour Burden Estimates for Initial Filings
Number of
Respondents
=
Aggregate
Number of
Responses2

Hours Per
Response3

Hours Per Response
Amortized Over 3
Years4

Aggregate
Hours
Amortized
Over 3 Years5

Requested

244 responses6

38 hours

÷ 3 =

13 hours

3,172 hours

Previously
Approved

374 responses

55 hours

÷ 3 =

18 hours

6,732 hours

Change

(130) responses

(17) hours

(5) hours

(3,560) hours

Requested

5 responses7

270 hours

÷ 3 =

90 hours

450 hours

Previously
Approved

14 responses

380 hours

÷ 3 =

127 hours

1,778 hours

Change

(9) responses

(110) hours

(37) hours

(1,328) hours

Requested

1 responses8

212 hours

÷ 3 =

71 hours

71 hours

Previously
Approved

1 response

229 hours

÷ 3 =

76 hours

76 hours

Change

No change

(17) hours

(5) hours

(5) hours

Requested

30 responses9

264 hours

÷ 3 =

88 hours

2,640 hours

Previously
Approved

18 responses

281 hours

÷ 3 =

94 hours

1,692 hours

Change

12 responses

(17) hours

(6) hours

948 hours

Respondent1

Smaller
Private
Fund
Advisers

Large Hedge
Fund
Advisers

Large
Liquidity
Fund
Advisers

Large
Private
Equity
Advisers

U.S. Securities and Exchange Commission (SEC)
Page 7 of 24

Notes:

1. We expect that the hourly burden will be most significant for the initial report because the adviser will

2.
3.
4.
5.
6.

7.

8.

9.

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.
This concerns the initial filing; therefore, we estimate one response per respondent. The proposed
changes are due to using updated data to estimate the number of advisers.
Hours per response changes are due to the proposed amendments.
We propose to amortize the initial time burden over three years because we believe that most of the
burden will be incurred in the initial filing.
(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
responses and (2) the proposed amendments.
We estimate based on Form PF data that 1,516 smaller private fund advisers would have filed Form PF
in the first quarter of 2025 if the proposed revised reporting thresholds were in effect. Based on filing
data from the last five years, an average of 16.1 percent of them would not have filed for the previous
due date. (1,516 x 0.161 = 244 advisers.)
We estimate based on Form PF data that 227 large hedge fund advisers would have filed Form PF in
the first quarter of 2025 if the proposed revised reporting thresholds were in effect. Based on filing data
from the last five years, an average of 2.3 percent of them would not have filed for the previous year.
(227 x 0.023 = 5 advisers.)
We estimate based on Form PF data that 20 large liquidity fund advisers would have filed Form PF in
the first quarter of 2025 if the proposed revised reporting thresholds were in effect. Based on filing data
from the last five years, an average of 1.5 percent of them would not have filed for the previous year.
(20 x 0.015 = 0.3 advisers, rounded up to 1 adviser.)
We estimate based on Form PF data that 541 large private equity advisers would have filed Form PF in
the first quarter of 2025 if the proposed revised reporting thresholds were in effect. Based on filing data
from the last five years, an average of 5.6 percent of them would not have filed for the previous due
date. (541 x 0.056 = 30 advisers.)

U.S. Securities and Exchange Commission (SEC)
Page 8 of 24

PRA Table 3: Annual Hour Burden Estimates for Ongoing Annual and Quarterly Filings
Respondent1
Smaller
Private
Fund
Advisers
Large
Hedge
Fund
Advisers
Large
Liquidit
y Fund
Advisers
Large
Private
Equity
Advisers

Requested

Number of
Respondents2
1,272
advisers6

Number of
Responses3

Hours Per
Response4

Aggregate
Hours5

x

1 response

x

18 hours

=

22,896 hours

2,376 advisers

x

1 response

x

22 hours

=

52,272 hours

Change

(1,104)
advisers

x

No change

(4) hours

=

(29,376) hours

Requested

222 advisers7

x

4 responses

x

123 hours

=

109,224 hours

Previously
Approved

556 advisers

x

4 responses

x

176 hours

=

391,424 hours

Change

(334) advisers

(53) hours

=

(282,200)
hours

Requested

19 advisers8

x

4 responses

x

82 hours

=

6,232 hours

Previously
Approved

20 advisers

x

4 responses

x

86 hours

=

6,880 hours

Change

(1) advisers

(4) hours

=

(648) hours

Requested

511 advisers9

x

1 response

x

141 hours

=

72,051 hours

Previously
Approved

432 advisers

x

1 response

x

145 hours

=

62,640 hours

Change

79 advisers

(4) hours

=

9,411 hours

Previously
Approved

No change

No change

U.S. Securities and Exchange Commission (SEC)
Page 9 of 24

No change

Notes:
1. 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.
2. Changes to the number of respondents are due to using updated data to estimate the number of advisers.
3. Smaller private fund advisers and large private equity advisers file annually. Large hedge fund advisers
and large liquidity fund advisers file quarterly.
4. Hours per response changes are due to the proposed amendments.
5. Changes to the aggregated hours are due to (1) using updated data to estimate the number of advisers
and (2) the proposed amendments.
6. We estimate based on Form PF data that 1,516 smaller private fund advisers would have filed Form PF
in the first quarter of 2025 if the proposed revised reporting thresholds were in effect. We estimated that
244 of them would have filed an initial filing, as discussed in PRA Table 2: Annual Hour Burden
Estimates for Initial Filings. (1,516 total smaller advisers – 244 advisers that made an initial filing =
1,272advisers that make ongoing filings.)
7. We estimate based on Form PF data that 227 large hedge fund advisers would have filed Form PF in the
first quarter of 2025. We estimated that 5 of them would have filed an initial filing, as discussed in PRA
Table 2: Annual Hour Burden Estimates for Initial Filings. (227 total large hedge fund advisers – 5
advisers that made an initial filing = 222 advisers that make ongoing filings.)
8. We estimate based on Form PF data that 20 large liquidity fund advisers would have filed Form PF in
the first quarter of 2025. We estimated that one of them would have filed an initial filing, as discussed in
PRA Table 2: Annual Hour Burden Estimates for Initial Filings. (20 total large liquidity fund advisers –
1 adviser that made an initial filing = 19 advisers that make ongoing filings.)
9. We estimate based on Form PF data that 541 large private equity advisers would have filed Form PF in
the first quarter of 2025. We estimated that 30 of them would have filed an initial filing, as discussed in
PRA Table 2: Annual Hour Burden Estimates for Initial Filings. (541 total large private equity advisers
– 30 advisers that made an initial filing = 511 advisers that make ongoing filings.)

U.S. Securities and Exchange Commission (SEC)
Page 10 of 24

PRA Table 4: Annual Hour Burden Estimates for Current Reporting and Private Equity Event
Reporting
Aggregate Number
Hours Per
Aggregate
Respondent1
of Responses
Response
Hours
Smaller Private
Fund Advisers

Large Hedge
Fund Advisers

Large Private
Equity
Advisers

Requested

0 responses

x

0 hours

=

0 hours

Previously
Approved

20 responses

x

5 hours

=

100 hours

Change

(20) responses

Requested

94 responses2

x

10 hours

=

940 hours

Previously
Approved

60 responses

x

10 hours

=

600 hours

Change

34 responses

Requested

0 responses

x

0 hours

=

0 hours

Previously
Approved

20 responses

x

5 hours

=

100 hours

Change

(20) responses

(5) hours

(100) hours

No change

(5) hours

340 hours3

(100) hours

Notes:
1. Under our proposal, section 6 (private equity event reporting) would be eliminated, removing this filing
obligation for private fund advisers that advise private equity funds. Large hedge fund advisers would
still file current reports in section 5.
2. We estimate based on Form PF data from the last two years that large hedge fund advisers would have
filed an average of 94 current reports annually if the proposed revised reporting thresholds were in effect.
3. Changes are due to using updated data to estimate the number of advisers and number of responses.

U.S. Securities and Exchange Commission (SEC)
Page 11 of 24

PRA Table 5: Annual Hour Burden Estimates for Transition Filings, Final Filings, and Temporary
Hardship Requests
Aggregate
Hours Per Response
Number of Responses2

Filing Type1

Transition Filing
from Quarterly to
Annual

Final Filings

Aggregate Hours3

Proposed
Estimate

16 responses4

x

0.25 hours

=

4 hours

Previously
Approved

69 responses

x

0.25 hours

=

17 hours

Change

(53) responses

Proposed
Estimate
Previously
Approved
Change

Proposed
Estimate
Temporary Hardship Previously
Requests
Approved
Change

No change

(13) hours

157 responses5

x

0.25 hours

=

39 hours

243 responses

x

0.25 hours

=

61 hours

(86) responses

No change

(22) hours

2 responses6

x

1 hour

=

2 hours

4 responses

x

1 hour

=

4 hours

(2) responses

No change

(2) hours

Notes:
1. Advisers make limited Form PF filings 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 filing
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.
2. Changes to the aggregate number of responses are due to using updated data.
3. Changes to the aggregate hours are due to the changes in the aggregate number of responses.
4. In the case of the proposed estimates, we estimate based on Form PF data that 227 advisers would have
filed quarterly reports in the first quarter of 2025. Based on filing data from the last five years, we
estimate an average of 7% would have filed a transition filing. (227 x 0.07 = 16 responses.)
5. In the case of the proposed estimates, we estimate based on Form PF data that 2,280 advisers would
have filed Form PF in the first quarter of 2025. Based on filing data from the last five years, an average
of 6.9% of them would have filed a final filing. (2,280 x 0.069 = approximately 157 responses.)
6. In the case of the proposed estimates, based on experience receiving temporary hardship requests, we
estimate that 1 out of 1,000 advisers would have filed a temporary hardship exemption annually. We
estimate based on Form PF data that 2,280 advisers would have filed Form PF in the first quarter of
2025. (2,280 / 1,000 = approximately 2 responses.)

U.S. Securities and Exchange Commission (SEC)
Page 12 of 24

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. 2

2

To calculate the occupational hourly rates used in this release, the Commission uses occupation-specific mean
hourly wage data from the Occupational Employment and Wage Statistics (OEWS) program of the Bureau of Labor
Statistics (BLS) for the securities industry (NAICS 523). See Occupational Employment and Wage Statistics, U.S.
BUREAU OF LABOR STATISTICS , https://www.bls.gov/oes/; see also Standard Occupational Classification, U.S.
BUREAU OF LABOR STATISTICS , https://www.bls.gov/soc/ (describing occupational classification system used by
BLS); EXEC. OFF . OF THE PRESIDENT, OFF . OF M GMT. & BUDGET, NORTH AMERICAN I NDUSTRY CLASSIFICATION
SYSTEM (2022), available at https://www.census.gov/naics/reference_files_tools/2022_NAICS_Manual.pdf
(describing the industry classification system used by BLS and other agencies). To account for any changes in
wages between the data reference period and when the data is released, the mean hourly wage for each occupation is
multiplied by the seasonally adjusted employment cost index for private wages and salaries. See Employment Cost
Index, U.S. BUREAU OF LABOR STATISTICS , https://www.bls.gov/eci/. The adjusted mean hourly wage is then
multiplied by a factor that accounts for nonwage costs, such as bonuses, benefits, and overhead. The nonwage cost
adjustment factor is calculated as an average over the 10 most recently available years of data of the ratio of the
Bureau of Economic Analysis’s annual gross output data for the securities industry to total annual wages across all
occupations for the securities industry’s OEWS data. See Gross Output by Industry, U.S. BUREAU OF ECONOMIC
ANALYSIS , https://www.bea.gov/data/industries/gross-output-by-industry; Occupational Employment and Wage
Statistics, U.S. BUREAU OF LABOR STATISTICS , https://www.bls.gov/oes/. The final product is the occupational
hourly rate. See generally UPDATED M ETHODOLOGY FOR CALCULATING OCCUPATIONAL H OURLY RATES (Dec. 19,
2025), available at https://www.sec.gov/files/method-occupational-hourly-rates.pdf.

U.S. Securities and Exchange Commission (SEC)
Page 13 of 24

PRA Table 6: Annual Monetized Time Burden of Initial Filings
Respondent1

Per Response
Per Response2 Amortized Over 3
years3

Aggregate
Number of
Responses4

Aggregate Monetized
Time Burden
Amortized Over 3
Years

Requested
Smaller
Private Previously
Approved
Fund
Advisers
Change

$21,5275

÷ 3 =

$7,176

x

244 responses

=

$1,750,944

$21,340

÷ 3 =

$7,113

x

374 responses

=

$2,660,262

Requested

$135,4596

÷ 3 =

$45,153

x

5 responses

=

$225,765

Previously
Approved

$139,080

÷ 3 =

$46,360

x

14 responses

=

$649,040

Change

($3,621)

Large
Liquidit
y Fund
Advisers

Requested

$106,3297

÷ 3 =

$35,443

x

1 response

=

$35,443

Previously
Approved

$83,792

÷ 3 =

$27,931

x

1 response

=

$27,931

Change

$22,537

Large
Private
Equity
Advisers

Requested

$132,3848

÷ 3 =

$44,128

x

30 responses

=

$1,323,840

Previously
Approved

$102,868

÷ 3 =

$34,289

x

18 responses

=

$617,202

Change

$29,516

Large
Hedge
Fund
Advisers

$187

(130)
responses

$63

($1,207)

(9) responses

$7,512

U.S. Securities and Exchange Commission (SEC)
Page 14 of 24

$9,839

($909,318)

($423,275)

No change

12 responses

$7,512

$706,638

Notes:
1. We expect that the monetized time burden will be most significant for the initial report, for the same
reasons discussed in PRA Table 2: Annual Hour Burden Estimates for Initial Filings. Accordingly, we
anticipate that the initial report will require more attention from senior personnel, including financial
managers and financial risk specialists, than will ongoing annual and quarterly filings. Changes are due
to using (1) updated hours per response estimates, as discussed in PRA Table 2: Annual Hour Burden
Estimates for Initial Filings, (2) updated aggregate number of responses, as discussed in PRA Table 2:
Annual Hour Burden Estimates for Initial Filings, and (3) updated wage estimates.
2. For the hours per response in each calculation, see PRA Table 2: Annual Hour Burden Estimates for
Initial Filings.
3. We propose to 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.
4. See PRA Table 2: Annual Hour Burden Estimates for Initial Filings.
5. For smaller private fund advisers, we estimate that the initial report will most likely be completed equally
by a financial manager at a cost of $731 per hour and a financial risk specialist at a cost of $402 per hour.
(($731 per hour x 0.5) + ($402 per hour x 0.5)) x 38 hours per response = $21,527.
6. For large hedge fund advisers, we estimate that for the initial report, of a total estimated burden of 270
hours, approximately 60 percent will most likely be performed by compliance professionals and 40
percent will most likely be performed by programmers working on system configuration and reporting
automation (that is approximately 162 hours for compliance professionals and approximately 108 hours
for programmers). Of the work performed by compliance professionals, we anticipate that it will be
performed equally by a financial manager at a cost of $731 per hour and a financial risk specialist at a
cost of $402 per hour. Of the work performed by programmers, we anticipate that it will be performed
equally by a software developer at a cost of $462 per hour and a computer systems analyst at a cost of
$347 per hour. (($731 per hour x 0.5) + ($402 per hour x 0.5)) x 162 hours = $91,773. (($462 per hour x
0.5) + ($347 per hour x 0.5)) x 108 hours = $43,686. $91,773 + $43,686 = $135,459.
7. For large liquidity fund advisers, we estimate that for the initial report, of a total estimated burden of 212
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 127 hours for compliance professionals
and 85 hours for programmers). Of the work performed by compliance professionals, we anticipate that
it will be performed equally by a financial manager at a cost of $731 per hour and a financial risk
specialist at a cost of $402 per hour. Of the work performed by programmers, we anticipate that it will be
performed equally by a software developer at a cost of $462 per hour and a computer systems analyst at a
cost of $347 per hour. (($731 per hour x 0.5) + ($402 per hour x 0.5)) x 127 hours = $71,946. (($462 per
hour x 0.5) + ($347 per hour x 0.5)) x 85 hours = $34,383. $71,946 + $34,383 = $106,329.
8. For large private equity advisers, we expect that for the initial report, of a total estimated burden of 264
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 158 hours for compliance professionals
and 106 hours for programmers). Of the work performed by compliance professionals, we anticipate that
it will be performed equally by a financial manager at a cost of $731 per hour and a financial risk
specialist at a cost of $402 per hour. Of the work performed by programmers, we anticipate that it will be
performed equally by a software developer at a cost of $462 per hour and a computer systems analyst at a
cost of $347 per hour. (($731 per hour x 0.5) + ($402 per hour x 0.5)) x 158 hours = $89,507. (($462 per
hour x 0.5) + ($347 per hour x 0.5)) x 106 hours = $42,877. $89,507 + $42,877 = $132,384.

U.S. Securities and Exchange Commission (SEC)
Page 15 of 24

PRA 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 Advisers

Aggregate Number
of Responses

Per Response2

Aggregate
Monetized Time
Burden

Requested

$8,5503

x

1,272 responses4

=

$10,875,600

Previously
Approved

$7,062

x

2,376 responses

=

$16,779,312

Change

$1,488

Requested

$58,4255

x

888 responses6

=

$51,881,400

Previously
Approved

$56,496

x

2,224 responses

=

$125,647,104

Change

$1,929

Requested

$38,9507

x

76 responses8

=

$2,960,200

Previously
Approved

$27,606

x

80 responses

=

$2,208,480

Change

$11,344

Requested

$66,9759

x

511 responses10

=

$34,224,225

Previously
Approved

$46,545

x

432 responses

=

$20,107,440

Change

$20,430

(1,104) responses

($5,903,712)

(1,336) responses

($73,765,704)

(4) responses

79 responses

$751,720

$14,116,785

Notes:
1. 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 PRA Table 3: Annual Hour Burden Estimates
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 PRA Table 3: Annual Hour
Burden Estimates for Ongoing Annual and Quarterly Filings, and (3) updated number of respondents,
as discussed in PRA Table 3: Annual Hour Burden Estimates for Ongoing Annual and Quarterly
Filings.
2. For all types of respondents, we estimate that both annual and quarterly reports would be completed (1)
25 percent by a financial manager at a cost of $731 per hour, (2) 25 percent by a financial examiner at a
cost of $365, and (3) 50 percent by a financial risk specialist at a cost of $402 per hour. ($731 x 0.25 =
$182.75) + ($365 x 0.25 = $91.25) + ($402 x 0.5 = $201) = $54.50) = $475. To calculate the cost per
response for each respondent, we used the hours per response from PRA Table 3: Annual Hour Burden
Estimates for Ongoing Annual and Quarterly Filings.
3. Cost per response for smaller private fund advisers: ($475 per hour x 18 hours per response = $8,550
per response.)
4. (1,272 smaller private fund advisers x 1 response annually = 1,272 aggregate responses.)
5. Cost per response for large hedge fund advisers: ($475 per hour x 123 hours per response = $58,425per
response.)
6. (222 large hedge fund advisers x 4 responses annually = 888 aggregate responses.)
7. Cost per response for large liquidity fund advisers: ($475 per hour x 82 hours per response = $38,950
per response.
8. (19 large liquidity fund advisers x 4 responses annually = 76 aggregate responses.)
9. Cost per response for large private equity advisers: ($475 per hour x 141 hours per response = $66,975
per response.)
10. (511 private equity advisers x 1 response annually = 511 aggregate responses.)
U.S. Securities and Exchange Commission (SEC)
Page 16 of 24

PRA 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
Advisers

Aggregate Monetized
Time Burden

Aggregate
Number of Responses2

Per Response
Requested

$0

x

0 responses

=

$0

Previously
Approved

$2,024

x

20 responses

=

$40,480

Change

($2,024)

Requested

$6,6443

x

94 responses

=

$624,536

Previously
Approved

$5,160

x

60 responses

=

$309,600

Change

$1,484

Requested

$0

x

0 responses

=

$0

Previously
Approved

$2,024

x

20 responses

=

$40,480

Change

($2,024)

(20) responses

($40,480)

34 responses

(20) responses

$314,936

($40,480)

Notes:
1. Under our proposal, section 6 (private equity event reporting) would be eliminated, removing any filing
obligations for advisers that advise private equity funds. Large hedge fund advisers would still file current
reports under section 5.
2. See PRA Table 4: Annual Hour Burden Estimates for Current Reporting.
3. For the cost per response for large hedge fund advisers, we estimate that, depending on the circumstances,
different legal professionals and financial professionals at the advisers would work on the section 5 current
report because the reporting events may require both legal and quantitative analysis. We estimate that the
time costs for a legal professional to be approximately $744. We estimate that the time costs for a financial
professional to be approximately $567, which is a blended average hourly rate for a financial risk specialist
($402) and a financial manager ($731). Of the total 10 hours that a section 5 current report would take, we
estimate that an adviser would spend on average 5.5 hours of lawyer time and 4.5 hours of financial
professional time to prepare, review, and submit a current report pursuant to section 5. (5.5 hours x $744 per
hour for a legal professional = $4,092) + (4.5 hours x $567 per hour for a financial professional = $2,552) =
$6,644.

U.S. Securities and Exchange Commission (SEC)
Page 17 of 24

PRA Table 9: Annual Monetized Time Burden for Transition Filings, Final Filings, and Temporary
Hardship Requests
Filing Type1
Transition Filing
from Quarterly to
Annual

Final Filings

Temporary
Hardship Requests

Per Response

Aggregate NumberAggregate Monetized Time
of Responses2
Burden

Proposed Estimate

$413

x

16 responses

=

$656

Previously
Approved

$21

x

69 responses

=

$1,415

Change

$20

Proposed Estimate

$414

x

157 responses

=

$6,437

$21

x

243 responses

=

$5,103

Previously
Approved
Change

(53) responses

$20

($759)

(86) responses

$1,334

Proposed Estimate

$5115

x

2 responses

=

$1,022

Previously
Approved

$252

x

4 responses

=

$1,008

Change

$259

(2) responses

$14

Notes:
1. Advisers make limited Form PF filings 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 filing 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.
2. See PRA Table 5: Annual Hour Burden Estimates for Transition Filings, Final Filings, and Temporary
Hardship Requests.
3. In the case of the proposed estimates, we estimate that each transition filing will take 0.25 hours and that a
bookkeeping, accounting, and auditing clerk would perform this work at a cost of $164 an hour. (0.25
hours x $164 = $41).
4. In the case of the proposed estimates, we estimate that each final filing will take 0.25 hours and that a
bookkeeping, accounting, and auditing clerk would perform this work at a cost of $164 an hour. (0.25
hours x $164 = $41).
5. In the case of the proposed estimates, we estimate that each temporary hardship request will take 1 hour.
We estimate that a financial manager would perform five-eighths of the work at a cost of $731 and a
general clerk would perform three-eighths of the work at a cost of $144. (1 hour x ((5/8 of an hour x $731
= $457) + (3/8 of an hour x $144 = $54)) = $511 per response.

U.S. Securities and Exchange Commission (SEC)
Page 18 of 24

d.

Summary of Estimates and Change in Burden

PRA Table 10: Aggregate Annual Estimates
Description1
Requested
Previously Approved
Change
2
Respondents
2,280 respondents
3,791 respondents
(1,511) respondents
3
Responses
3,296 responses
5,935 responses
(2,639) responses
4
Time Burden
217,721 hours
524,376 hours
(306,655) hours
Monetized Time Burden
$103,911,0685
$169,094,737
($65,183,669)
(Dollars)
External Cost Burden (Dollars)
$2,113,1526
$2,938,977
($825,825)
Notes:
1. Changes are due to (1) the proposed amendments, (2) using updated data, and (3) using different
methodologies to calculate certain estimates, as described in this PRA.
2. We estimate based on Form PF data that the following advisers would have filed Form PF in the
first quarter of 2025: 1,516 smaller private fund advisers + 227 large hedge fund advisers + 20
large liquidity fund advisers + 541 large private equity advisers - 34 advisers in overlapping
categories = 2,280 advisers.
3. Under our proposal, for initial filings (PRA Table 2): (244 smaller private fund adviser responses +
5 large hedge fund adviser responses + 1 large liquidity fund adviser response + 30 large private
equity adviser responses = 280 responses.) For ongoing annual and quarterly filings (PRA Table
3): (1,272 smaller private fund adviser responses + 888 large hedge fund adviser responses + 76
large liquidity fund adviser responses + 511 large private equity adviser responses = 2,747
responses.) For current reporting (PRA Table 4): (94 large hedge fund adviser responses). (280
responses for initial filings + 2,747 responses for ongoing annual and quarterly filings + 94
responses for current reports + 16 responses for transition filings + 157 responses for final filings +
2 responses for temporary hardship requests = 3,296 responses.)
4. Under our proposal, for initial filings: (3,172 hours for smaller private fund advisers + 450 hours
for large hedge fund advisers + 71 hours for large liquidity fund advisers + 2,640 hours for large
private equity advisers = 6,333 hours). For ongoing annual and quarterly filings: (22,896 hours for
smaller private fund advisers + 109,224 hours for large hedge fund advisers + 6,232 for hours large
liquidity fund advisers + 72,051 hours for large private equity advisers = 210,403). For current
reporting: (940 hours for large hedge fund advisers). (6,333 hours for initial filings + 210,403 for
ongoing annual and quarterly filings + 940 hours for current reporting + 4 hours for transition
filings + 39 hours for final filings + 2 hours for temporary hardship requests = 217,721 hours.
5. Under our proposal, for initial filings: ($1,750,944 for smaller private fund advisers + $225,765 for
large hedge fund advisers + $35,443 for large liquidity fund advisers + $1,323,840 for large private
equity advisers = $3,335,992). For ongoing annual and quarterly filings: ($10,875,600 for smaller
private fund advisers + $51,881,400 for large hedge fund advisers + $2,960,200 for large liquidity
fund advisers + $34,224,225 for large private equity advisers = $99,941,425). For current reports:
($624,536for large hedge fund advisers). ($3,335,992 for initial filings + $99,941,425 for ongoing
annual and quarterly filings + $624,536 for current reports + $1,656 for transition filings + $6,437
for final filings + $1,022 for temporary hardship requests = $103,911,068.
6. Under our proposal, for the external cost burden for annual, quarterly, and initial filings:
($1,040,652 for smaller private fund advisers + $252,865 for large hedge fund advisers + $28,667
for large liquidity fund advisers + $581,160 for large private equity advisers = $1,903,344). For
current reporting: ($209,808 for large hedge fund advisers). $1,903,344 + $209,808 = $2,113,152.

U.S. Securities and Exchange Commission (SEC)
Page 19 of 24

13.

Estimated Additional Cost Burden
We estimate an aggregate annual estimated external cost burden of $2,113,152, which represents

a decrease of $825,825from the previously approved estimate of $2,938,977. See Table 10: Aggregate
Annual Estimates, above, 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.

U.S. Securities and Exchange Commission (SEC)
Page 20 of 24

PRA Table 11: Annual External Cost Burden for Ongoing Annual and Quarterly Filings as well as Initial Filings
Aggregate
External External Cost
Filing
Total
Number of
External Cost
Number
Cost of of Initial Filing
Total Aggregate
Fee Per Filing
Respondent1 Responses Per
of Initial of Initial Filing
External Cost8
Initial Amortized Over
2
3
6
Filing
Fees
Filings Amortized Over 3
Respondent
3 Years5
Filing 4
Years7
Proposed
1 x $150 = $150 $10,000 ÷ 3 = $3,333 x 244
= $813,252
$1,040,652 9
Estimate
Smaller
Previously
1 x $150 = $150 $10,000 ÷ 3 = $3,333 x 374
= $1,246,542
$1,659,042
Private
Approved
Fund
N/A
N/A
N/A
N/A
(130)
($433,290)
($618,390)
Advisers Change N/A
Proposed
Large Estimate 4 x
Hedge Previously
Fund Approved 4 x
Advisers
Change N/A
Proposed
4 x
Large Estimate
Liquidity Previously
Fund Approved 4 x
Advisers
Change N/A
Proposed
Large Estimate 1 x
Private
Previously
1 x
Equity
Approved
Fund
Advisers Change N/A

$150

=

$600 $70,000 ÷ 3 = $23,333

x

5

=

$116,665

$252,865 10

$150

=

$600 $70,000 ÷ 3 = $23,333

x

14

=

$326,662

$668,662

($209,997)

($415,797)

N/A

N/A

N/A

N/A

(9)

$150

=

$600 $50,000 ÷ 3 = $16,667

x

1

=

$16,667

$28,667 11

$150

=

$600 $50,000 ÷ 3 = $16,667

x

1

=

$16,667

$29,267

N/A

($600)

N/A

N/A

N/A

N/A

N/A

$150

=

$150 $50,000 ÷ 3 = $16,667

x

30

=

$500,010

$581,160 12

$150

=

$150 $50,000 ÷ 3 = $16,667

x

18

=

$300,006

$367,656

$200,004

$213,504

N/A

N/A

N/A

U.S. Securities and Exchange Commission (SEC)
Page 21 of 24

N/A

12

Notes:
1. 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 that Form PF requires.
2. Smaller private fund advisers and large private equity fund advisers file annually. Large hedge fund advisers and large liquidity
fund advisers file quarterly.
3. 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)].
4. 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. Staff also estimated that 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. Given the proposed amendments, we estimate that the external cost burden for
smaller private fund advisers would range from $0 to $10,000, per smaller private fund adviser. This range reflects the amendments
and is designed to reflect that the cost to any smaller private fund adviser may depend on how many funds or the type of funds it
manages, the state of its existing systems, and the complexity of its business. We use the upper range to calculate the estimate for
smaller private fund advisers: $10,000. Also, given the amendments, in our proposed estimates, we estimate that the external cost
burden for initial filings for large liquidity fund advisers, and large private equity fund advisers would continue to range from $0 to
$50,000 for the same reasons as the current estimates for those types of advisers. We used the upper range to calculate the
estimates: $50,000. Additionally, given the amendments, in our proposed estimates, we estimate that the external cost burden for
initial filings for large hedge fund advisers would continue to range from $0 to $70,000 for the same reasons as the current estimates
for those types of advisers. We used the upper range to calculate the estimates: $70,000.
5. 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 will be incurred in the initial filing.
6. See PRA Table 2: Annual Hour Burden Estimates for Initial Filings.
7. Changes to the aggregate external cost of initial filings, amortized over three years are due to (1) the proposed amendments and (2)
using updated data.
8. Changes to the total aggregate external cost are due to (1) the proposed amendments and (2) using updated data.
9. We estimate based on Form PF data that 1,516 smaller private fund advisers would have filed Form PF in the first quarter of
2025. (1,516 smaller private fund advisers x $150 total filing fees) + $813,252 aggregate external cost of initial filing amortized
over three years = $1,040,652 total aggregate external cost.
10. We estimate based on Form PF data that 227 large hedge fund advisers would have filed Form PF in the first quarter of 2025. (227
large hedge fund advisers x $600 total filing fees) + $116,665 aggregate external cost of initial filing amortized over three years =
$252,865 total aggregate external cost.
11. We estimate based on Form PF data that 20 large liquidity fund advisers would have filed Form PF in the first quarter of 2025. (20
large liquidity fund advisers x $600 total filing fees) + $16,667 aggregate external cost of initial filing amortized over three years =
$28,667 total aggregate external cost.
12. We estimate based on Form PF data that 541 large private equity advisers would have filed Form PF in the first quarter of
2025. (541 large private equity fund advisers x $150 total filing fees) + $500,010 aggregate external cost of initial filing amortized
over three years = $581,160 total aggregate external cost.

U.S. Securities and Exchange Commission (SEC)
Page 22 of 24

PRA Table 12: Annual External Cost Burden for Current Reporting and Private Equity Event
Reporting1
Aggregate
Number of
Responses

Respondent
Smaller
Private
Fund
Advisers
Large Hedge
Fund
Advisers
Large
Private
Equity Fund
Advisers

Cost of Outside
Counsel Per
Current Report

Total Aggregate
External Cost2

Proposed Estimate

0

x

0

=

0

Previously Approved

20

x

$1,695

=

$33,900

Change

(20)

Proposed Estimate

94

x

$2,2323

=

$209,808

Previously Approved

60

x

$1,695

=

$101,700

Change

34

Proposed Estimate

0

x

0

=

0

Previously Approved

20

x

$1,695

=

$33,900

Change

(20)

($1,695)

($33,900)

$537

($1,695)

$108,108

($33,900)

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

1. Under our proposal, section 6 (private equity event reporting) would be eliminated, removing this filing obligation
for advisers that advise private equity funds. Large hedge fund advisers would still file current reports in section
5.
2. (Aggregate number of responses) + (aggregate cost of outside counsel) = total aggregate external cost.
3. We estimate the cost for a lawyer is $744. We estimate that approximately 3 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 lawyers. The hour estimate reflects our decreased hour burden for current reporting. (3 hours x $744 for
outside legal services = $2,232.)

14.

Annual Cost to the Federal Government

The SEC is in the process of revising its methodologies to estimate annualized costs to the
Federal government for all its relevant collections of information. The SEC anticipates that future
extensions of this collection of information will reflect the revised methodologies.

15.

Reasons for Changes in Burden Estimates

The aggregate annual estimate of 2,280 respondents represents a decrease of 1,511 respondents
from the previously approved estimate of 3,791 respondents. The aggregate annual estimate of 3,296
responses represents a decrease of 2,639 responses from the previously approved estimate of 5,935
responses. The aggregate annual estimated time burden of 217,721 hours represents a decrease of
306,655 hours from the previously approved estimate of 524,376 hours. The aggregate annual estimated
monetized time burden of $103,911,0685 represents a decrease of $65,183,669 from the previously
approved estimate of $169,094,737. The aggregate annual estimated external cost burden of $2,113,152
represents a decrease of $825,825 from the previously approved estimate of $2,938,977. The changes
are due to the proposed amendments, updated data, and using a new methodology for certain estimates.
U.S. Securities and Exchange Commission (SEC)
Page 23 of 24

These changes in burden also reflect the SEC’s revision and update of burden estimates for all
information collections under this OMB control number (whether or not associated with rulemaking
changes), and the SEC requested public comment on all information collection burden estimates for this
OMB control number.)

16.

Plans for Publishing Results
Not applicable.

17.

Approval to Omit Display of 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 the Certification for Paperwork Reduction Act Submissions
Not applicable.

U.S. Securities and Exchange Commission (SEC)
Page 24 of 24