UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549 

FORM PF

NOTE: This version of Form PF includes amendments that are effective and other amendments that are not yet 

effective. More information about applicable effective and compliance dates of certain amendments may be found in 

Form PF; Event Reporting for Large Hedge Fund Advisers and Private Equity Fund Advisers; Requirements for 

Large Private Equity Fund Adviser Reporting (May 3, 2023) [88 FR 38146 (June 12, 2023)] available at 

https://www.sec.gov/files/rules/final/2023/ia-6297.pdf. A reference copy of the version of Form PF that does not 

reflect the above amendments is available at https://www.sec.gov/divisions/investment/pfrd/pfrdfaq.shtml. 

This is a reference copy of Form PF. You may not send a completed printout of this form to the SEC to satisfy a 

filing obligation. You can only satisfy an SEC filing obligation by submitting the information required by this form 

to the SEC in electronic format online at the Private Fund Reporting Depository (“PFRD”). More information on 

PFRD is available at https://www.iard.com/pfrd/default. 
SEC 2048 (12-23) 

FORM PF (Paper Version)

Reporting Form for Investment Advisers to

Private Funds and Certain Commodity Pool

Operators and Commodity Trading Advisors

Read these instructions carefully before completing Form PF. Failure to follow these instructions, properly

complete Form PF, or pay all required fees may result in your Form PF being delayed or rejected.

In these instructions and in Form PF, “you” means the private fund adviser completing or amending this

Form PF. If you are a “separately identifiable department or division” (SID) of a bank, “you” means the

SID rather than the bank (except as provided in Question 1(a)). Terms that appear in italics are defined in

the Glossary of Terms to Form PF.

1. Who must complete and file a Form PF?

You must complete and file a Form PF, if:

A. You are registered or required to register with the SEC as an investment adviser;

OR

You are registered or required to register with the CFTC as a CPO or CTA and you are

also registered or required to register with the SEC as an investment adviser;

AND

B. You manage one or more private funds.

AND

C. You and your related persons, collectively, had at least $150 million in private fund assets

under management as of the last day of your most recently completed fiscal year.

Many private fund advisers meeting these criteria will be required to complete only Section 1 of

Form PF and will need to file only on an annual basis. Large private fund advisers, however, will be 

required to provide additional data, and large hedge fund advisers and large liquidity fund advisers

will need to file every quarter. Large hedge fund advisers will need to file a current report in Section 

5 and advisers to private equity funds will need to file a current report in Section 6, upon certain 

current reporting events. See Instructions 3, 9, and 12 below. 

For purposes of determining whether you meet the reporting threshold, you are not required to

include the regulatory assets under management of any related person that is separately operated. 

See Instruction 5 below for more detail.

If your principal office and place of business is outside the United States, for purposes of this Form

PF you may disregard any private fund that, during your last fiscal year, was not a United States

person, was not offered in the United States, and was not beneficially owned by any United States

person. 

2. I have a related person who is required to file Form PF. May I and my related person file a single

Form PF?

Related persons may (but are not required to) report on a single Form PF information with respect to

all such related persons and the private funds they advise. You must identify in your response

Form PF: General Instructions Page 1

OMB APPROVAL

OMB Number: 3235-0679 

Expires: March 31, 2027 

Estimated average burden

hours per response: 76.62
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Form PF: General Instructions Page 2 

to Question 1 the related persons as to which you are reporting and, where information is requested

about you or the private funds you advise, respond as though you and such related persons were

one firm.

3. How is Form PF organized?

Section 1 – All Form PF filers

Section 1a All private fund advisers required to file Form PF must complete Section 1a. Section

1a asks general identifying information about you and the types of private funds you

advise.

Section 1b All private fund advisers required to file Form PF must complete Section 1b. Section

1b asks for certain information regarding the private funds that you advise.

Section 1c All private fund advisers that are required to file Form PF and advise one or more

hedge funds must complete Section 1c. Section 1c asks for certain information

regarding the hedge funds that you advise.

Section 2 – Large hedge fund advisers

Section 2a You are required to complete Section 2a if you and your related persons, 

collectively, had at least $1.5 billion in hedge fund assets under management as of

the last day of any month in the fiscal quarter immediately preceding your most

recently completed fiscal quarter. You are not required to include the regulatory

assets under management of any related person that is separately operated. 

Subject to Instruction 4, Section 2a requires information to be reported on an

aggregate basis for all hedge funds that you advise.

Section 2b If you are required to complete Section 2a, you must complete a separate Section 2b

with respect to each qualifying hedge fund that you advise.

However:

if you are reporting separately on the funds of a parallel fund structure that, in the

aggregate, comprises a qualifying hedge fund, you must complete a separate Section

2b for each parallel fund that is part of that parallel fund structure (even if that

parallel fund is not itself a qualifying hedge fund); and

if you report answers on an aggregated basis for any master-feeder arrangement or 

parallel fund structure in accordance with Instruction 5, you should only complete a 

separate Section 2b with respect to the reporting fund for such master- feeder

arrangement or parallel fund structure. 

Section 3 – Large liquidity fund advisers

Section 3 You are required to complete Section 3 if (i) you advise one or more liquidity funds

and (ii) as of the last day of any month in the fiscal quarter immediately preceding

your most recently completed fiscal quarter, you and yourrelated persons, collectively,
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Form PF: General Instructions Page 3 

had at least $1 billion in combined money market and liquidity fund assets under

management. You are not required to include the regulatory assets under

management of any related person that is separately operated. 

You must complete a separate Section 3 with respect to each liquidity fund that you

advise.

However, if you report answers on an aggregated basis for any master-feeder

arrangement or parallel fund structure in accordance with Instruction 5, you should

only complete a separate Section 3 with respect to the reporting fund for such

master-feeder arrangement or parallel fund structure. 

Section 4 – Large private equity fund advisers

Section 4 You are required to complete Section 4 if you and your related persons, 

collectively, had at least $2 billion in private equity fund assets under management

as of the last day of your most recently completed fiscal year. You are not required

to include the regulatory assets under management of any related person that is

separately operated. 

You must complete a separate Section 4 with respect to each private equity fund

that you advise.

However, if you report answers on an aggregated basis for any master-feeder

arrangement or parallel fund structure in accordance with Instruction 5, you should

only complete a separate Section 4 with respect to the reporting fund for such

master-feeder arrangement or parallel fund structure. 

Section 5 – Current report for large hedge fund advisers to qualifying hedge funds

Section 5 Section 5 is the current reporting form for large hedge fund advisers to qualifying 

hedge funds. You must complete and file Section 5 for any current reporting event

with respect to a qualifying hedge fund you advise.

Section 6 – Quarterly event report for advisers to private equity funds

Section 6 Section 6 is the quarterly event reporting form about private equity funds. You must 

complete and file Section 6 for any private equity reporting event with respect to a 

private equity fund you advise.

Section 7 – Advisers requesting a temporary hardship exemption

Section 7 See Instruction 14 for details.

4. I am a subadviser or engage a subadviser for a private fund. Who is responsible for reporting

information about that private fund?

Only one private fund adviser should complete and file Form PF for each private fund. If the 

adviser that filed Form ADV Section 7.B.1 with respect to any private fund is required to file Form

PF, the same adviser must also complete and file Form PF for that private fund. If the adviser that

filed Form ADV Section 7.B.1 with respect to any private fund is not required to file Form PF (e.g., 

because it is an exempt reporting adviser) and one or more other advisers to the fund is required to

file Form PF, another adviser must complete and file Form PF for that private fund. 

Where a question requests aggregate information regarding the private funds that you advise, you

should only include information regarding the private funds for which you are filing Section 1b of

Form PF.
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Form PF: General Instructions Page 4 

5. When am I required to aggregate information regarding parallel funds, parallel managed accounts, 

master-feeder arrangements and funds managed by related persons?

You are required to aggregate related funds and accounts differently depending on the purpose of

the aggregation.

Reporting thresholds. For purposes of determining whether you meet any reporting threshold, you

must aggregate parallel funds, dependent parallel managed accounts and master-feeder funds. In

addition, you must treat any private fund or parallel managed account advised by any of your

related persons as though it were advised by you. You are not required, however, to aggregate

private funds or parallel managed accounts of any related person that is separately operated. 

Responding to questions. When reporting on individual funds, you may provide information

regarding master-feeder arrangements or parallel fund structures either in the aggregate or 

separately, provided that you do so consistently throughout the Form. (For example, you may

complete either a single Section 1b for all of the funds in a master-feeder arrangement or a separate

Section 1b for each fund in the arrangement, but you must then take the same approach when

completing other applicable sections of the Form.) Where a question requests aggregate information

regarding the private funds that you advise, you should only include information regarding the 

private funds for which you are filing Section 1b of Form PF. You are not required to report

information regarding parallel managed accounts (except in Question 11). You should not report

information for any private fund advised by any of your related persons unless you have identified 

that related person in Question 1(b) as a related person for which you are filing Form PF.

See the table below for additional details.

For purposes of determining whether a

private fund is a qualifying hedge fund

For purposes of reporting information in

Sections 1b, 1c, 2b, 3 and 4

You must aggregate any private funds that

are part of the same master-feeder

arrangement (even if you did not, or were

not permitted to, aggregate these private

funds for purposes of Form ADV Section

7.B.1) 

You may, but are not required to, report

answers on an aggregated basis for any 

private funds that are part of the same

master-feeder arrangement (even if you

did not, or were not permitted to, aggregate

these private funds for purposes of Form

ADV Section 7.B.1) 

 You must aggregate any private funds that

are part of the same parallel fund structure

 You may, but are not required to, report

answers on an aggregated basis for any 

private funds that are part of the same

parallel fund structure

 Any dependent parallel managed account

must be aggregated with the largest private

fund to which that dependent parallel

managed account relates

 You are not required to report information

regarding parallel managed accounts

(except in Question 11)

You must treat any private fund or parallel 

managed account advised by any of your

related persons as though it were advised

by you (including related persons that you

have not identified in Question 1(b) as

related persons for which you are filing

Form PF, though you may exclude related

persons that are separately operated) 

You should not report information for any

private fund advised by any of your related

persons unless you have identified that

related person in Question 1(b) as a related

person for which you are filing Form PF
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Form PF: General Instructions Page 5 

6. I am required to aggregate funds or accounts to determine whether I meet a reporting

threshold, or I am electing to aggregate funds for reporting purposes. How do I “aggregate”

funds or accounts for these purposes?

Where two or more parallel funds or master-feeder funds are aggregated in accordance with

Instruction 5, you must treat the aggregated funds as if they were all one private fund. 

Investments that a feeder fund makes in a master fund should be disregarded but other investments

of the feeder fund should be treated as though they were investments of the aggregated fund. 

Where you are aggregating dependent parallel managed accounts to determine whether you meet a 

reporting threshold, assets held in the accounts should be treated as assets of the private funds with

which they are aggregated.

Example 1. You advise a master-feeder arrangement with one feeder fund. The feeder

fund has invested $500 in the master fund and holds a foreign exchange

derivative with a notional value of $100. The master fund has used the

$500 received from the feeder fund to invest in corporate bonds. Neither fund 

has any other assets or liabilities.

For purposes of determining whether the funds comprise a qualifying hedge

fund, this master-feeder arrangement should be treated as a single private fund 

whose only investments are $500 in corporate bonds and a foreign exchange

derivative with a notional value of $100. If you elect to aggregate the masterfeeder arrangement for reporting purposes, the treatment would be the same.

Example 2. You advise a parallel fund structure consisting of two hedge funds, named

parallel fund A and parallel fund B. You also advise a related dependent

parallel managed account. The account and each fund have invested in

corporate bonds of Company X and have no other assets or liabilities. The

value of parallel fund A’s investment is $400, the value of parallel fund B’s

investment is $300 and the value of the account’s investment is $200.

For purposes of determining whether either of the parallel funds is a qualifying

hedge fund, the entire parallel fund structure and the related dependent 

parallel managed account should be treated as a single private fund whose

only asset is $900 of corporate bonds issued by Company X.

If you elect to aggregate the parallel fund structure for reporting purposes, you

would disregard the dependent parallel managed account, so the result would

be a single private fund whose only asset is $700 of corporate bonds issued by 

Company X. 

7. I advise a private fund that invests in other private funds (e.g., a “fund of funds”). How should 

 I treat these investments for purposes of Form PF?

Investments in other private funds generally. For purposes of this Form PF, you may disregard any 

private fund's equity investments in other private funds. However, if you disregard these 

investments, you must do so consistently (e.g., do not include disregarded investments in the net

asset value used for determining whether the fund is a “hedge fund”). For Question 17, even if you

disregard these assets, you may report the performance of the entire fund and are not required to 

recalculate performance in order to exclude these investments. Do not disregard any liabilities,

even if incurred in connection with these investments.

Funds that invest substantially all of their assets in other private funds. If you advise a private fund
6 

Form PF: General Instructions Page 6 

that (i) invests substantially all of its assets in the equity of private funds for which you are not an 

adviser and (ii) aside from such private fund investments, holds only cash and cash equivalents and 

instruments acquired for the purpose of hedging currency exposure, then you are only required to

complete Section 1b for that fund. For all other purposes, you should disregard such fund. For

example, where questions request aggregate information regarding the private funds you advise, do

not include the assets or liabilities of any such fund. 

Solely for purposes of this Instruction 7, you may treat as a private fund any issuer formed under the

laws of a jurisdiction other than the United States that has not offered or sold its securities in the 

United States or to United States persons but that would be a private fund if it had engaged in such 

an offering or sale.

Notwithstanding the foregoing, you must include disregarded assets in responding to Question 10.

8. I advise a private fund that invests in companies that are not private funds. How should I treat

these investments for purposes of Form PF?

Except as provided in Instruction 7, investments in funds should be included for all purposes under 

this Form PF. You are not, however, required to “look through” a fund’s investments in any other

entity unless the Form specifically requests information regarding that entity or the other entity’s

primary purpose is to hold assets or incur leverage as part of the reporting

fund's investment activities.

9. When am I required to update Form PF?

You are required to update Form PF at the following times:

Periodic filings

(large hedge fund

advisers)

Within 60 calendar days after the end of your first, second and third fiscal

quarters, you must file a quarterly update that updates the answers to all

Items in this Form PF relating to the hedge funds that you advise.

Within 60 calendar days after the end of your fourth fiscal quarter, you must

file a quarterly update that updates the answers to all Items in this Form PF.

You may, however, submit an initial filing for the fourth quarter that

updates information relating only to the hedge funds that you advise so long

as you amend your Form PF within 120 calendar days after the end of the

quarter to update information relating to any other private funds that you 

advise. When you file such an amendment, you are not required to update 

information previously filed for such quarter.

Periodic filings

(large liquidity

fund advisers)

Within 15 calendar days after the end of your first, second and third fiscal

quarters, you must file a quarterly update that updates the answers to all

Items in this Form PF relating to the liquidity funds that you advise.

Within 15 calendar days after the end of your fourth fiscal quarter, you must

file a quarterly update that updates the answers to all Items in this Form PF.

You may, however, submit an initial filing for the fourth quarter that updates

information relating only to the liquidity funds that you advise so long as you

amend your Form PF within 120 calendar days after the end of 

the quarter to update information relating to any other private funds that you

advise (subject to the next paragraph). When you file such an amendment,

you are not required to update information previously filed for such quarter.
7 

Form PF: General Instructions Page 7 

If you are both a large liquidity fund adviser and a large hedge fund adviser, 

you must file your quarterly updates with respect to the liquidity funds that

you advise within 15 calendar days and with respect to the hedge funds you

advise within 60 calendar days.

Periodic filings

(all other advisers)

Within 120 calendar days after the end of your fiscal year, you must file an

annual update that updates the answers to all Items in this Form PF.

Large hedge fund advisers and large liquidity fund advisers are not required

to file annual updates but instead file quarterly updates for the fourth quarter.

Transition filing If you are transitioning from quarterly to annual filing because you are no 

longer a large hedge fund adviser or large liquidity fund adviser, then you must

complete and file Item A of Section 1a and check the box in

Section 1a indicating that you are making your final quarterly filing. You

must file your transition filing no later than the last day on which your next

quarterly update would be timely.

Current reports

(large hedge fund 

advisers)

Large hedge fund advisers must file a current report in Section 5 upon certain 

current reporting events with respect to qualifying hedge funds they advise. See 

Section 5 for filing deadlines.

Private Equity 

Event Reports 

(all advisers to 

private equity 

funds) 

All advisers to private equity funds must file a private equity event report in 

Section 6 upon certain private equity reporting events with respect to private 

equity funds they advise within 60 calendar days after the end of their first,

second, third, and fourth fiscal quarters. 

Final filing If you are no longer required to file Form PF, then you must complete and

file Item A of Section 1a and check the box in Section 1a indicating that you

are making your final filing. You must file your final filing no later

than the last day on which your next Form PF update would be timely. This

applies to all Form PF filers.

Failure to update your Form PF as required by these instructions is a violation of SEC and,

where applicable, CFTC rules and could lead to revocation of your registration.

10. How do I obtain private fund identification numbers for my reporting funds?

Each private fund must have an identification number for purposes of reporting on Form ADV and 

Form PF. Private fund identification numbers can only be obtained by filing Form ADV. 

If you need to obtain a private fund identification number and you are required to file a quarterly

update of Form PF prior to your next annual update of Form ADV, then you must acquire the 

identification number by filing an other-than-annual amendment to your Form ADV and following

the instructions on Form ADV for generating a new number. When filing an other-than-annual

amendment for this purpose, you must complete and file all of Form ADV Section

7.B.1 for the new private fund. 

See Instruction 6 to Part 1A of Form ADV for additional information regarding the acquisition and 

use of private fund identification numbers.
8 

Form PF: General Instructions Page 8 

11. Who must sign my Form PF or update?

The individual who signs the Form PF depends upon your form of organization: 

• For a sole proprietorship, the sole proprietor.

• For a partnership, a general partner.

• For a corporation, an authorized principal officer.

• For a limited liability company, a managing member or authorized person.

• For a SID, a principal officer of your bank who is directly engaged in the management,

direction or supervision of your investment advisory activities.

• For all others, an authorized individual who participates in managing or directing your affairs. 

The signature does not have to be notarized and should be a typed name.

If you and one or more of your related persons are filing a single Form PF, then Form PF may be 

signed by one or more individuals; however, the individual, or the individuals collectively, must

have authority, as provided above, to sign both on your behalf and on behalf of all such related

persons. 

12. How do I file my Form PF?

You must file Form PF electronically through the Form PF filing system on the Investment Adviser

Registration Depository website (www.iard.com), which contains detailed filing instructions. 

Questions regarding filing through the Form PF filing system should be addressed to the

Financial Industry Regulatory Authority (FINRA) at 240-386-4848. 

If you are a large hedge fund adviser filing a current report in Section 5, only file Section 5. Do not 

file any other sections of the form. If you are an adviser to private equity funds filing a current 

report in Section 6 only file Section 6. Do not file any other sections of the form. For all other types 

of filings, file the applicable sections as provided in Instruction 3.

13. Are there filing fees?

Yes, you must pay a filing fee for your Form PF filings. The Form PF filing fee schedule is

published at https://www.sec.gov/iard and http://www.iard.com.

14. What if I am not able to file electronically?

A temporary hardship exemption is available if you encounter unanticipated technical difficulties

that prevent you from making a timely filing with the Form PF filing system, such as a computer

malfunction or electrical outage. This exemption does not permit you to file on paper; instead, it

extends the deadline for an electronic filing for seven “business days” (as such term is used in SEC

rule 204(b)-1(f)).

To request a temporary hardship exemption, you must complete and file on paper Item A of Section

1a and Section 7 of Form PF, checking the box in Section 1a indicating that you are requesting a 

temporary hardship exemption. Mail one manually signed original and one copy of your exemption

filing to: U.S. Securities and Exchange Commission, Branch of Regulations and

Examinations, Mail Stop 0-25, 100 F Street NE, Washington, DC 20549. You must preserve in your

records a copy of any temporary hardship exemption filing. Any request for a temporary hardship

exemption must be filed no later than one business day after the electronic Form PF filing was due. 

For more information, see SEC rule 204(b)-1(f).

15. May I rely on my own methodologies in responding to Form PF? How should I enter

requested information?

You may respond to this Form using your own internal methodologies and the conventions of your
9 

Form PF: General Instructions Page 9 

service providers, provided the information is consistent with information that you report internally

and to current and prospective investors. However, your methodologies must be consistently

applied and your responses must be consistent with any instructions or other guidance relating to this

Form. You may explain any of your methodologies, including related assumptions, in Question 4. 

In responding to Questions on this Form, the following guidelines apply unless otherwise

specifically indicated: 

 provide the requested information as of the close of business on the data reporting date; 

 if information is requested for any month or quarter, provide the requested information as of the 

close of business on the last calendar day of the month or quarter, respectively;

 if a question requests information expressed as a percentage, enter the response as a percentage

(not a decimal) and round to the nearest one percent;

 if a question requests a monetary value, provide the information in U.S. dollars as of the data

reporting date, rounded to the nearest thousand;

 if a question requests a numerical value other than a percentage or a dollar value, provide

information rounded to the nearest whole number;

 if a question requests information regarding a “position” or “positions,” you should determine

whether a set of legal and contractual rights constitutes a “position” in a manner consistent with

your internal recordkeeping and risk management procedures (e.g., some advisers may record as

a single position two or more partially offsetting legs of a transaction entered into with the same

counterparty under the same master agreement, while others may record these as separate

positions);

 if a question requires you to distinguish long positions from short positions, classify positions in 

a manner consistent with your internal recordkeeping and risk management procedures

(provided that, for CDS, exotic CDS, index CDS, and single name CDS, the protection seller

should be viewed as long and the protection buyer should be viewed as short);

 do not net long and short positions;

 for derivatives (other than options), “value” means gross notional value; for options, “value”

means delta adjusted notional value; for all other investments and for all borrowings where the 

reporting fund is the creditor, “value” means market value or, where there is not a readily

available market value, fair value; for borrowings where the reporting fund is the debtor,

“value” means the value you report internally and to current and prospective investors; and 

 for questions 20, 21, 25, 28, and 35, the numerator you use to determine the percentage of net

asset value should be measured on the same basis as gross asset value and may result in

responses that total more than 100%. 

16. How do I amend Form PF, for example, to make a correction?

If you discover that information you filed on Form PF was not accurate at the time of filing, you

may correct the information by re-filing and checking the box in Section 1a, Section 5 or Section 6, 

as applicable, indicating that you are amending a previously submitted filing. You are not required

to update information that you believe in good faith properly responded to Form PF on the date of

filing even if that information is subsequently revised for purposes of your recordkeeping, risk

management or investor reporting (such as estimates that are refined after completion of a 

subsequent audit).

Large hedge fund advisers and large liquidity fund advisers that comply with their fourth quarter
10 

Form PF: General Instructions Page 10 

filing obligations by submitting an initial filing followed by an amendment in accordance with

Instruction 9 will not be viewed as affirming responses regarding one fund solely by providing

updated information regarding another fund at a later date.

17. How may I preserve on Form PF the anonymity of a private fund that I advise?

If you seek to preserve the anonymity of a private fund that you advise by maintaining its identity in 

your books and records in numerical or alphabetical code, or similar designation, pursuant to rule

204-2(d), you may identify the private fund on Form PF using the same code or designation in place

of the fund’s name.

18. May I report on Form PF regarding a commodity pool that is not a private fund? How should I

treat the commodity pool for purposes of Form PF?

If you are otherwise required to report on Form PF, you may report information regarding any 

commodity pool you advise on Form PF, even if it is not a private fund. Properly reporting on Form

PF regarding the commodity pool will constitute substitute compliance with CFTC reporting

requirements to the extent provided in CEA rule 4.27. 

Commodity pools should be treated as hedge funds for purposes of Form PF. If you are reporting on 

Form PF regarding a commodity pool that is not a private fund, then treat it as a private fund for 

purposes of Form PF. However, such a commodity pool is not required to be included when

determining whether you exceed one or more reporting thresholds. If such a commodity pool is a 

qualifying hedge fund and you are otherwise required to report information in section 2a of 

Form PF, then you must report regarding the commodity pool in section 2b of Form PF.

Federal Information Law and Requirements for a Collection of Information

Section 204(b) of the Advisers Act [15 U.S.C. 80b-4(b)] authorizes the SEC to collect the information that

Form PF requires. 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 to assist FSOC in 

determining whether and how to deploy its regulatory tools with respect to nonbank financial companies.

The SEC and CFTC may also use information collected on Form PF in their regulatory programs, including

examinations, investigations and investor protection efforts relating to private fund advisers. Filing Form PF

is mandatory for advisers that satisfy the criteria described in Instruction 1 to the Form. See also 17 C.F.R. § 

275.204(b)-1. The SEC does not intend to make public information reported on Form PF that is identifiable

to any particular adviser or private fund, although the SEC may use Form PF information in an enforcement

action. See Section 204(b) of the Advisers Act. 

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 control number. The Office of Management and Budget has 

reviewed this collection of information under 44 U.S.C. 3507. Any member of the public may direct any 

comments concerning the accuracy of the burden estimate and any suggestion for reducing this burden to:

Secretary, U.S. Securities and Exchange Commission, 100 F Street NE, Washington, DC 20549.
Form PF

Section 1a

Information about you and your related persons

(to be completed by all Form PF filers)

Page 1 of 53 

Check the box that indicates what you would like to do:

A. If you are not a large hedge fund adviser or large liquidity fund adviser: 

Submit your first filing on Form PF 

for the period ended: ___________________ 

Submit an annual update

for the period ended: ___________________ 

Amend a previously submitted filing 

for the period ended: ___________________ 

Submit a final filing

Request a temporary hardship exemption

B. If you are a large hedge fund adviser or large liquidity fund adviser: 

Submit your first filing on Form PF

for the [1st, 2nd, 3rd, 4th] quarter, which ended: ___________________

Submit a quarterly update (including fourth quarter updates)

for the [1st, 2nd, 3rd, 4th] quarter, which ended: ___________________

Amend a previously submitted filing

for the [1st, 2nd, 3rd, 4th] quarter, which ended: ___________________ 

Transition to annual reporting

Submit a final filing

Request a temporary hardship exemption

Item A. Information about you

1. (a) Provide your name and the other identifying information requested below. 

(This should be your full legal name. If you are a sole proprietor, this will be your last,

first, and middle names. If you are a SID, enter the full legal name of your bank.

Please use the same name that you use in your Form ADV.)

Legal name SEC 801-Number

NFA ID

Number, if any

Large trader

ID, if any

Large trader

ID suffix, if any

(b) Provide the following information for each of the related persons, if any, with respect to

which you are reporting information on this Form PF:

Legal name SEC 801-Number

NFA ID

Number, if any

Large trader

ID, if any

Large trader

ID suffix, if any

Section 1a: Information about you and your related persons
Form PF

Section 1a

Information about you and your related persons

(to be completed by all Form PF filers)

Page 2 of 53 

2. Signatures of sole proprietor or authorized representative (see Instruction 11 to Form PF). 

Signature on behalf of the firm and its related persons:

I, the undersigned, sign this Form PF on behalf of, and with the authority of, the firm. In

addition, I sign this Form PF on behalf of, and with the authority of, each of the related

persons identified in Question 1(b) (other than any related person for which another

individual has signed this Form PF below). 

To the extent that Section 1 or 2 of this Form PF is filed in accordance with a regulatory

obligation imposed by CEA rule 4.27, the firm, each related person for which I am signing

this Form PF, and I shall accept that any false or misleading statement of a material fact therein or 

material omission therefrom shall constitute a violation of section 6(c)(2) of the CEA. 

Name of individual: 

Signature:

Title:

Email address:

Telephone contact number (include area code and, if 

outside the United States, country code):

Date:

Signature on behalf of related persons:

I, the undersigned, sign this Form PF on behalf of, and with the authority of, the related

person(s) identified below. 

To the extent that Section 1 or 2 of this Form PF is filed in accordance with a regulatory

obligation imposed by CEA rule 4.27, each related person identified below and I shall accept

that any false or misleading statement of a material fact therein or material omission therefrom

shall constitute a violation of section 6(c)(2) of the CEA. 

Name of each related person on behalf of which this

individual is signing:

Name of individual: 

Signature:

Title:

Email address:

Telephone contact number (include area code and, if 

outside the United States, country code):

Date:
Form PF

Section 1a

Information about you and your related persons

(to be completed by all Form PF filers)

Page 3 of 53 

Item B. Information about assets of private funds that you advise

3. Provide a breakdown of your regulatory assets under management and your net assets under

management as follows:

(If you are filing a quarterly update for your first, second or third fiscal quarter, you are only

required to update row (a), in the case of a large hedge fund adviser, or row (b), in the case 

of a large liquidity fund adviser.)

Regulatory assets 

under management

Net assets under

management

(a) Hedge funds ......................................................

(b) Liquidity funds ..................................................

(c) Private equity funds ..........................................

(d) Real estate funds...............................................

(e) Securitized asset funds ......................................

(f) Venture capital funds........................................

(g) Other private funds...........................................

(h) Funds and accounts other than private funds 

(i.e., the remainder of your assets under

management).....................................................

Item C. Miscellaneous

4. You may use the space below to explain any assumptions that you made in responding to

any question in this Form PF. Assumptions must be in addition to, or reasonably follow

from, any instructions or other guidance relating to Form PF. If you are aware of any

instructions or other guidance that may require a different assumption, provide a citation

and explain why that assumption is not appropriate for this purpose.

Question

number Description
Form PF

Section 1b

Information about the private funds you advise

(to be completed by all Form PF filers)

Page 4 of 53 

Subject to Instruction 5, you must complete a separate Section 1b for each private fund that you advise.

Item A. Reporting fund identifying information

5. (a) Name of the reporting fund ...............................................................

(b) Private fund identification number of the reporting fund ................. 

(c) NFA identification number of the reporting fund, if applicable ........ 

(d) LEI of the reporting fund, if applicable.............................................

6. Check “yes” below if the reporting fund is the master fund of a master-feeder arrangement and 

you are reporting for all of the funds in the master-feeder arrangement on an aggregated basis.

Otherwise, check “no.”

(See Instruction 5 for information regarding aggregation of master-feeder arrangements. If you

respond “yes,” do not complete a separate Section 1b, 1c, 2b, 3 or 4 with respect to any of the

feeder funds.)

Yes No

7. (a) Check “yes” below if the reporting fund is the largest fund in a parallel fund structure and 

you are reporting for all of the funds in the structure on an aggregated basis. Otherwise,

check “no.” 

(See Instruction 5 for information regarding aggregation of parallel funds. If you respond

“yes,” do not complete a separate Section 1b, 1c, 2b, 3 or 4 with respect to any of the other

parallel funds in the structure.)

Yes No

If you responded “yes” to Question 7(a), complete (b) through (e) below for each other parallel

fund in the parallel fund structure. 

(b) Name of the parallel fund..................................................................

(c) Private fund identification number of the parallel fund .................... 

(d) NFA identification number of the parallel fund, if applicable .......... 

(e) LEI of the parallel fund, if applicable................................................

Item B. Assets, financing and investor concentration

8. Gross asset value of reporting fund..........................................................................

(This amount may differ from the amount you reported in response to question 11 of Form

ADV Section 7.B.1. For instance, the amounts may not be the same if you are filing Form PF

on a quarterly basis, if you are aggregating a master-feeder arrangement for purposes of this

Form PF and you did not aggregate that master-feeder arrangement for purposes of Form

ADV Section 7.B.1. or if you are aggregating parallel funds for purposes of this Form PF.)

9. Net asset value of reporting fund..............................................................................

Section 1b: Information about the private funds you advise
Form PF

Section 1b

Information about the private funds you advise

(to be completed by all Form PF filers)

Page 5 of 53 

10. Value of reporting fund's investments in equity of other private funds ...................

11. Value of all parallel managed accounts related to the reporting fund .....................

(If any of your parallel managed accounts relates to more than one of the private funds you 

advise, only report the value of the account once, in connection with the largest private fund to

which it relates.)

12. Provide the following information regarding the value of the reporting fund's borrowings and 

the types of creditors.

(You are not required to respond to this question for any reporting fund with respect to which

you are answering Question 43 in Section 2b or Question 68 in Section 4. Do not net out

amounts that the reporting fund loans to creditors or the value of collateral pledged to

creditors.)

(The percentages borrowed from the specified types of creditors should add up to

approximately 100%.)

(a) Dollar amount of total borrowings............................................................................

(b) Percentage borrowed from U.S. financial institutions.............................................. 

(c) Percentage borrowed from non-U.S. financial institutions.......................................

(d) Percentage borrowed from U.S. creditors that are not financial institutions ............

(e) Percentage borrowed from non-U.S. creditors that are not financial institutions.....

13. (a) Does the reporting fund have any outstanding derivatives positions?

Yes No

(b) If you responded “yes” to Question 13(a), provide the aggregate value of all

derivatives positions of the reporting fund................................................................ 

(You are not required to respond to Question 13 for any reporting fund with respect to which

you are answering Question 44 in Section 2b.)

14. Provide a summary of the reporting fund's assets and liabilities categorized using the hierarchy 

below. For assets and liabilities that you report internally and to current and prospective

investors as representing fair value, or for which you are required to determine fair value in 

order to report the reporting fund's regulatory assets under management on Form ADV, 

categorize them into the following categories based on the valuation assumptions utilized:

Level 1 – Quoted prices (unadjusted) in active markets for identical assets or liabilities.

Level 2 – Other than quoted prices included within Level 1 that are observable for the asset or

liability, either directly or indirectly.

Level 3 – Unobservable inputs, such as your assumptions or the fund’s assumptions used to

determine the fair value of the asset or liability.

For any assets and liabilities that you report internally and to current and prospective investors

as representing a measurement attribute other than fair value, and for which you are not 

required to determine fair value in order to report the reporting fund's regulatory assets under 

management on Form ADV, separately report these assets and liabilities in the “cost-based”

measurement column.

(If the fund’s financial statements are prepared in accordance with U.S. generally accepted 

accounting principles (“U.S. GAAP”) or another accounting standard that requires the
Form PF

Section 1b

Information about the private funds you advise

(to be completed by all Form PF filers)

Page 6 of 53 

categorization of assets and liabilities using a fair value hierarchy similar to that established

under U.S. GAAP, then respond to this question using the fair value hierarchy established

under the applicable accounting standard.)

(This question requires the use of fair values and cost-based measurements, which may be 

different from the values contemplated by Instruction 15. You are only required to respond to

this question if you are filing an annual update or a quarterly update for your fourth fiscal

quarter.)

Fair value

Level 1 Level 2 Level 3 Cost-based

Assets $______________ $______________ $______________ $______________ 

Liabilities $______________ $______________ $______________ $______________ 

15. Specify the approximate percentage of the reporting fund's equity that is beneficially 

owned by the five beneficial owners having the largest equity interests in the

reporting fund. 

(For purposes of this question, if you know that two or more beneficial owners of the reporting

fund are affiliated with each other, you should treat them as a single beneficial owner.)

16. Specify the approximate percentage of the reporting fund's equity that is beneficially owned by the 

following groups of investors.

(Include each investor in only one group. The total should add up to approximately 100%. With

respect to beneficial interests outstanding prior to March 31, 2012, that have not been transferred on 

or after that date, you may respond to this question using good faith estimates based on data

currently available to you.)

(a) Individuals that are United States persons (including their trusts)............................

(b) Individuals that are not United States persons (including their trusts)...................... 

(c) Broker-dealers ....................................................................................................

(d) Insurance companies.................................................................................................

(e) Investment companies registered with the SEC......................................................... 

(f) Private funds.............................................................................................................. 

(g) Non-profits.................................................................................................................

(h) Pension plans (excluding governmental pension plans)............................................ 

(i) Banking or thrift institutions (proprietary) ................................................................ 

(j) State or municipal government entities (excluding governmental pension plans) .... 

(k) State or municipal governmental pension plans........................................................ 

(l) Sovereign wealth funds and foreign official institutions........................................... 

(m) Investors that are not United States persons and about which the foregoing

beneficial ownership information is not known and cannot reasonably be obtained

because the beneficial interest is held through a chain involving one or more thirdparty intermediaries...................................................................................................

(n) Other.......................................................................................................................... 
Form PF

Section 1b

Information about the private funds you advise

(to be completed by all Form PF filers)

Page 7 of 53 

Item C. Reporting fund performance

17. Provide the reporting fund's gross and net performance, as reported to current and prospective 

investors (or, if calculated for other purposes but not reported to investors, as so calculated). If the

fund reports different performance results to different groups of investors, provide the most

representative results. You are required to provide monthly and quarterly performance results only 

if such results are calculated for the reporting fund (whether for purposes of reporting to current or 

prospective investors or otherwise).

(If your fiscal year is different from the reporting fund’s fiscal year, then for any portion of the

reporting fund’s fiscal year that has not been completed as of the data reporting date, provide the 

relevant information from that portion of the reporting fund’s preceding fiscal year.)

(Enter your responses as percentages rounded to the nearest one-hundredth of one percent. 

Performance results for monthly and quarterly periods should not be annualized. If any period 

precedes the date of the fund's formation, enter “NA”. You are not required to include 

performance results for any period with respect to which you previously provided performance

results for the reporting fund on Form PF.)

Last day of fiscal

period

Gross

performance

Net of

management fees

and incentive fees

and allocations

(a) 1st month of reporting fund's fiscal year ......

(b) 2nd month of reporting fund's fiscal year.....

(c) 3rd month of reporting fund's fiscal year......

(d) First quarter....................................................

(e) 4th month of reporting fund's fiscal year......

(f) 5th month of reporting fund's fiscal year......

(g) 6th month of reporting fund's fiscal year......

(h) Second quarter...............................................

(i) 7th month of reporting fund's fiscal year......

(j) 8th month of reporting fund's fiscal year......

(k) 9th month of reporting fund's fiscal year......

(l) Third quarter..................................................

(m) 10th month of reporting fund's fiscal year....

(n) 11th month of reporting fund's fiscal year....

(o) 12th month of reporting fund's fiscal year....

(p) Fourth quarter ................................................

(q) Reporting fund's most recently completed 

fiscal year.......................................................
Form PF

Section 1c

Information about the hedge funds you advise

(to be completed by all Form PF filers that advise hedge funds) 

Page 8 of 53 

Subject to Instruction 5, you must complete a separate Section 1c for each hedge fund that you advise.

Item A. Reporting fund identifying information

18. (a) Name of the reporting fund.........................................................................................

(b) Private fund identification number of the reporting fund ...........................................

Item B. Certain information regarding the reporting fund

19. Does the reporting fund have a single primary investment strategy or multiple strategies?

Single primary strategy Multi-strategy

20. Indicate which of the investment strategies below best describe the reporting fund's 

strategies. For each strategy that you have selected, provide a good faith estimate of the 

percentage of the reporting fund's net asset value represented by that strategy. If, in your 

view, the reporting fund's allocation among strategies is appropriately represented by the 

percentage of deployed capital, you may also provide that information.

(Select the investment strategies that best describe the reporting fund's strategies, even if 

the descriptions below do not precisely match your characterization of those strategies;

select “other” only if a strategy that the reporting fund uses is significantly different from

any of the strategies identified below. You may refer to the reporting fund’s use of these

strategies as of the data reporting date or throughout the reporting period, but you must

report using the same basis in future filings.)

(The strategies listed below are mutually exclusive (i.e., do not report the same assets

under multiple strategies). If providing percentages of capital, the total should add up to 

approximately 100%.)

Strategy % of NAV

(required)

% of capital

(optional)

Equity, Market Neutral

Equity, Long/Short

Equity, Short Bias

Equity, Long Bias

Macro, Active Trading

Macro, Commodity

Macro, Currency

Macro, Global Macro

Section 1c: Information about the hedge funds you advise
Form PF

Section 1c

Information about the hedge funds you advise

(to be completed by all Form PF filers that advise hedge funds) 

Page 9 of 53 

Relative Value, Fixed Income Asset Backed

Relative Value, Fixed Income Convertible Arbitrage

Relative Value, Fixed Income Corporate

Relative Value, Fixed Income Sovereign

Relative Value, Volatility Arbitrage

Event Driven, Distressed/Restructuring

Event Driven, Risk Arbitrage/Merger Arbitrage

Event Driven, Equity Special Situations

Credit, Long/Short

Credit, Asset Based Lending

Managed Futures/CTA, Fundamental

Managed Futures/CTA, Quantitative

Investment in other funds

Other: ______________ 

21. During the reporting period, approximately what percentage of the reporting fund's net 

asset value was managed using high-frequency trading strategies?

(In your response, please do not include strategies using algorithms solely for trade

execution. This question concerns strategies that are substantially computer-driven,

where decisions to place bids or offers, and to buy or sell, are primarily based on

algorithmic responses to intraday price action in equities, futures and options, and where

the total number of shares or contracts traded throughout the day is generally

significantly larger than the net change in position from one day to the next.)

0% less than 10% 10-25% 26-50%

51-75% 76-99% 100% or more

22. Identify the five counterparties to which the reporting fund has the greatest mark-to- market net

counterparty credit exposure, measured as a percentage of the reporting fund's net asset value. 

(For purposes of this question, you should treat affiliated entities as a single group to the extent

exposures may be contractually or legally set-off or netted across those entities and/or one affiliate

guarantees or may otherwise be obligated to satisfy the obligations of another. CCPs should not be 

regarded as counterparties for purposes of this question.)

(In your response, you should take into account: (i) mark-to-market gains and losses on derivatives; 

and (ii) any loans or loan commitments.)

(However, you should not take into account: (i) margin posted by the counterparty; or

(ii) holdings of debt or equity securities issued by the counterparty.)
Form PF

Section 1c

Information about the hedge funds you advise

(to be completed by all Form PF filers that advise hedge funds) 

Page 10 of 53

Legal name of the counterparty

(or, if multiple affiliated entities,

counterparties)

Indicate below if the

counterparty is affiliated with

a major financial institution

Exposure (% of

reporting fund’s

net asset value)

(a)

(b) 

(c)

(d) 

(e)

23. Identify the five counterparties that have the greatest mark-to-market net counterparty

credit exposure to the reporting fund, measured in U.S. dollars.

(For purposes of this question, you should treat affiliated entities as a single group to the

extent exposures may be contractually or legally set-off or netted across those entities

and/or one affiliate guarantees or may otherwise be obligated to satisfy the obligations of

another. CCPs should not be regarded as counterparties for purposes of this question.)

(In your response, you should take into account: (i) mark-to-market gains and losses on

derivatives; and (ii) any loans or loan commitments.)

(However, you should not take into account: (i) margin posted to the counterparty; or

(ii) holdings of debt or equity securities issued by the counterparty.)

Legal name of the counterparty

(or, if multiple affiliated entities,

counterparties)

Indicate below if the

counterparty is affiliated with

a major financial institution

Exposure (in U.S. 

dollars)

(a)

(b) 

(c)

(d) 

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]

[drop-down list of counterparty names]

Other: ____________ 

[Not applicable]
Form PF

Section 1c

Information about the hedge funds you advise

(to be completed by all Form PF filers that advise hedge funds) 

Page 11 of 53

(e)

24. Provide the following information regarding your use of trading and clearing mechanisms

during the reporting period. 

(Provide good faith estimates of the mode in which instruments were traded and cleared by the 

reporting fund, and not the market as a whole. For purposes of this question, a “trade” includes any

transaction, whether entered into on a bilateral basis or through an exchange, trading facility or other

system and whether long or short. With respect to clearing, transactions for which margin is held in a 

customer omnibus account at a CCP should be considered cleared by a CCP. Tri-party repo applies

where repo collateral is held at a custodian (not including a CCP) that acts as a third party agent to

both the repo buyer and the repo seller.)

(The total in each part of this question should add up to 100%. Enter “NA” in each part of this

question for which the reporting fund engaged in no relevant trades.)

%

(a) Estimated % (in terms of value) of securities (other than derivatives) that

were traded by the reporting fund: 

On a regulated exchange ...........................................................................

OTC ...........................................................................................................

(b) Estimated % (in terms of trade volumes) of derivatives that were traded by 

the reporting fund: 

On a regulated exchange or swap execution facility ................................

OTC ..........................................................................................................

(c) Estimated % (in terms of trade volumes) of derivatives that were traded by 

the reporting fund and:

Cleared by a CCP.....................................................................................

Bilaterally transacted (i.e., not cleared by a CCP) ...................................

(d) Estimated % (in terms of value) of repo trades that were entered into by the

reporting fund and:

Cleared by a CCP.....................................................................................

Bilaterally transacted (i.e., not cleared by a CCP) ...................................

Constitute a tri-party repo ........................................................................

25. What percentage of the reporting fund's net asset value relates to transactions 

that are not described in any of the categories listed in items (a) through (d) of

Question 24?

[drop-down list of counterparty names]

Other:____________ 

[Not applicable]
Form PF

Section 2a

Aggregated information about hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 12 of 53

Item A. Exposure of hedge fund assets

26. Aggregate hedge fund exposures.

(Give a dollar value for long and short positions as of the last day in each month of the reporting period, 

by sub-asset class, including all exposure whether held physically, synthetically or through derivatives.

Enter “NA” in each space for which there are no relevant positions.)

(Include any closed out and OTC forward positions that have not yet expired/matured. Do not net

positions within sub-asset classes. Positions held in side-pockets should be included as positions of the

hedge funds. Provide the absolute value of short positions. Each position should only be included in a 

single sub-asset class.)

(Where “duration/WAT/10-year eq.” is required, provide at least one of the following with respect to the 

position and indicate which measure is being used: bond duration, weighted average tenor or 10-year

bond equivalent. Duration and weighted average tenor should be entered in terms of years to two

decimal places.)

1st Month 2nd Month 3rd Month

 LV SV LV SV LV SV

Listed equity

Issued by financial institutions .................. 

Other listed equity...................................... 

Unlisted equity

Issued by financial institutions .................. 

Other unlisted equity.................................. 

Listed equity derivatives

Related to financial institutions ................. 

Other listed equity derivatives................... 

Derivative exposures to unlisted equities

Related to financial institutions ................. 

Other derivative exposures to unlisted

equities........................ ............................... 

Corporate bonds issued by financial

institutions (other than convertible bonds) 

Investment grade .......................................

Duration WAT 10-year eq..

Non-investment grade ............................... 

Duration WAT 10-year eq..

Section 2a: Aggregated information about hedge funds that you advise
Form PF

Section 2a

Aggregated information about hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 13 of 53

Corporate bonds not issued by financial

institutions (other than convertible bonds) 

Investment grade .......................................

Duration WAT 10-year eq..

Non-investment grade ............................... 

Duration WAT 10-year eq..

Convertible bonds issued by financial

institutions

Investment grade .......................................

Duration WAT 10-year eq..

Non-investment grade ............................... 

Duration WAT 10-year eq..

Convertible bonds not issued by financial

institutions

Investment grade .......................................

Duration WAT 10-year eq..

Non-investment grade ............................... 

Duration WAT 10-year eq..

Sovereign bonds and municipal bonds

U.S. treasury securities..............................

Duration WAT 10-year eq..

Agency securities .......................................

Duration WAT 10-year eq..

GSE bonds .................................................

Duration WAT 10-year eq..

Sovereign bonds issued by G10 countries

other than the U.S. ..................................... 

Duration WAT 10-year eq..

Other sovereign bonds (including

supranational bonds).................................. 

Duration WAT 10-year eq..

U.S. state and local bonds.......................... 

Duration WAT 10-year eq..

Loans 

Leveraged loans ........................................
Form PF

Section 2a

Aggregated information about hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 14 of 53

Duration WAT 10-year eq..

Other loans (not including repos).............. 

Duration WAT 10-year eq..

Repos ................................................................

Duration WAT 10-year eq. ....... 

ABS/structured products

MBS ........................................................... 

Duration WAT 10-year eq..

ABCP ......................................................... 

Duration WAT 10-year eq..

CDO/CLO.................................................. 

Duration WAT 10-year eq..

Other ABS.................................................. 

Duration WAT 10-year eq..

Other structured products .........................

Credit derivatives

Single name CDS ......................................

Index CDS .................................................

Exotic CDS ................................................

Foreign exchange derivatives (investment) ..... 

Foreign exchange derivatives (hedging).......... 

Non-U.S. currency holdings............................. 

Interest rate derivatives....................................

Commodities (derivatives)

Crude oil ....................................................

Natural gas ................................................

Gold ...........................................................

Power......................................................... 

Other commodities.....................................

Commodities (physical)

Crude oil ....................................................

Natural gas ................................................
Form PF

Section 2a

Aggregated information about hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 15 of 53

Gold ...........................................................

Power......................................................... 

Other commodities.....................................

Other derivatives ..............................................

Physical real estate ........................................... 

Investments in internal private funds ............... 

Investments in external private funds............... 

Investments in registered investment

companies.........................................................

Cash and cash equivalents

Certificates of deposit ............................... 

Duration WAT 10-year eq..

Other deposits ............................................ 

Money market funds...................................

Other cash and cash equivalents

(excluding government securities)............. 

Investments in funds for cash management

purposes (other than money market funds)....... 

Investments in other sub-asset classes .............

27. For each month of the reporting period, provide the value of turnover during the month in

each of the asset classes listed below for the hedge funds that you advise.

(The value of turnover should be the sum of the absolute values of transactions in the

relevant asset class during the period.)

Listed equity .....................................................

Corporate bonds (other than convertible

bonds)...............................................................

Convertible bonds ............................................

Sovereign bonds and municipal bonds

U.S. treasury securities..............................

Agency securities .......................................

GSE bonds .................................................

Sovereign bonds issued by G10 countries

other than the U.S. ..................................... 

Other sovereign bonds (including

supranational bonds).................................. 

1st Month 2nd Month 3rd Month
Form PF

Section 2a

Aggregated information about hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 16 of 53

U.S. state and local bonds.......................... 

Futures.............................................................. 

28. (a) Provide a geographical breakdown of the investments held by the hedge funds that you advise (by 

percentage of the total net asset value of these hedge funds).

(See Instruction 15 for information on calculating the numerator for purposes of 

this Question.)

Region % of NAV

(i) Africa .............................................................................................................

(ii) Asia and Pacific (other than the Middle East) ............................................... 

(iii) Europe (EEA)................................................................................................. 

(iv) Europe (other than EEA)................................................................................ 

(v) Middle East .................................................................................................... 

(vi) North America ............................................................................................... 

(vii) South America ............................................................................................... 

(viii) Supranational ................................................................................................. 

(b) Provide the value of investments in the following countries held by the hedge funds that you

advise (by percentage of the total net asset value of these hedge funds).

(See Instruction 15 for information on calculating the numerator for purposes of

this Question.)

Country % of NAV

(i) Brazil..............................................................................................................

(ii) China (including Hong Kong) ....................................................................... 

(iii) India ............................................................................................................... 

(iv) Japan .............................................................................................................. 

(v) Russia............................................................................................................. 

(vi) United States .................................................................................................. 
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 17 of 53

You must complete a separate Section 2b for each qualifying hedge fund that you advise. However, with

respect to master-feeder arrangements and parallel fund structures that collectively comprise qualifying

hedge funds, you may report collectively or separately about the component funds as provided in the

General Instructions.

Item A. Reporting fund identifying information

29. (a) Name of the reporting fund .........................................................................................

(b) Private fund identification number of the reporting fund ...........................................

Item B. Reporting fund exposures and trading

Check this box if you advise only one hedge fund. If you check this box, you may skip Question 30. 

30. Reporting fund exposures.

(Give a dollar value for long and short positions as of the last day in each month of the

reporting period, by sub-asset class, including all exposure whether held physically,

synthetically or through derivatives. Enter “NA” in each space for which there are no 

relevant positions.)

(Include any closed out and OTC forward positions that have not yet expired/matured. Do not

net positions within sub-asset classes. Positions held in side-pockets should be included as 

positions of the hedge funds. Provide the absolute value of short positions. Each position

should only be included in a single sub-asset class.)

(Where “duration/WAT/10-year eq.” is required, provide at least one of the following with

respect to the position and indicate which measure is being used: bond duration, weighted

average tenor or 10-year bond equivalent. Duration and weighted average tenor should be

entered in terms of years to two decimal places.)

Listed equity

Issued by financial institutions .................. 

Other listed equity...................................... 

Unlisted equity

Issued by financial institutions ..................

Other unlisted equity.................................. 

1st Month 2nd Month 3rd Month

LV SV LV SV LV SV

Section 2b: Information about qualifying hedge funds that you advise.
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 18 of 53

Listed equity derivatives

Related to financial institutions ................. 

Other listed equity derivatives................... 

Derivative exposures to unlisted equities

Related to financial institutions ................. 

Other derivative exposures to unlisted

equities....................................................... 

Corporate bonds issued by financial

institutions (other than convertible bonds) 

Investment grade .......................................

Duration WAT 10-year eq..

Non-investment grade .............................. 

Duration WAT 10-year eq..

Corporate bonds not issued by financial

institutions (other than convertible bonds) 

Investment grade .......................................

Duration WAT 10-year eq..

Non-investment grade ............................... 

Duration WAT 10-year eq..

Convertible bonds issued by financial

institutions

Investment grade .......................................

Duration WAT 10-year eq..

Non-investment grade ............................... 

Duration WAT 10-year eq..

Convertible bonds not issued by financial

institutions

Investment grade .......................................

Duration WAT 10-year eq..

Non-investment grade ............................... 

Duration WAT 10-year eq..

Sovereign bonds and municipal bonds

U.S. treasury securities..............................

Duration WAT 10-year eq..
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 19 of 53

Agency securities .......................................

Duration WAT 10-year eq..

GSE bonds .................................................

Duration WAT 10-year eq..

Sovereign bonds issued by G10 countries

other than the U.S. ..................................... 

Duration WAT 10-year eq..

Other sovereign bonds (including

supranational bonds).................................. 

Duration WAT 10-year eq..

U.S. state and local bonds.......................... 

Duration WAT 10-year eq..

Loans 

Leveraged loans ........................................

Duration WAT 10-year eq..

Other loans (not including repos).............. 

Duration WAT 10-year eq..

Repos ................................................................

Duration WAT 10-year eq. ....... 

ABS/structured products

MBS ........................................................... 

Duration WAT 10-year eq..

ABCP ......................................................... 

Duration WAT 10-year eq..

CDO/CLO.................................................. 

Duration WAT 10-year eq..

Other ABS.................................................. 

Duration WAT 10-year eq..

Other structured products .........................

Credit derivatives

Single name CDS ......................................

Index CDS .................................................

Exotic CDS ................................................

Foreign exchange derivatives (investment) ..... 

Foreign exchange derivatives (hedging) .......... 

Non-U.S. currency holdings.............................
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 20 of 53

Interest rate derivatives....................................

Commodities (derivatives)

Crude oil ....................................................

Natural gas ................................................

Gold ...........................................................

Power......................................................... 

Other commodities.....................................

Commodities (physical)

Crude oil ....................................................

Natural gas ................................................

Gold ...........................................................

Power......................................................... 

Other commodities.....................................

Other derivatives ..............................................

Physical real estate ........................................... 

Investments in internal private funds ............... 

Investments in external private funds............... 

Investments in registered investment

companies.........................................................

Cash and cash equivalents

Certificates of deposit ............................... 

Duration WAT 10-year eq..

Other deposits ............................................ 

Money market funds...................................

Other cash and cash equivalents

(excluding government securities)............. 

Investments in funds for cash management

purposes (other than money market funds)....... 

Investments in other sub-asset classes .............

31. What is the reporting fund's base currency? 

[drop-down of currencies]

Other: ______________ 
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 21 of 53

32. Provide the following information regarding the liquidity of the reporting fund's portfolio. 

(Specify the percentage by value of the reporting fund’s positions that may be liquidated

within each of the periods specified below. Each investment should be assigned to only one

period and such assignment should be based on the shortest period during which you believe

that such position could reasonably be liquidated at or near its carrying value. Use good 

faith estimates for liquidity based on market conditions over the reporting period and

assuming no fire-sale discounting. In the event that individual positions are important

contingent parts of the same trade, group all those positions under the liquidity period of the 

least liquid part (so, for example, in a convertible bond arbitrage trade, the liquidity of the 

short should be the same as the convertible bond). Exclude cash and cash equivalents.)

(The total should add up to approximately 100%.)

1 day or less ................................................................................................ 

2 days – 7 days............................................................................................

8 days – 30 days.......................................................................................... 

31 days – 90 days........................................................................................ 

91 days – 180 days...................................................................................... 

181 days – 365 days.................................................................................... 

Longer than 365 days.................................................................................. 

% of portfolio

capable of being

liquidated within

33. Value of reporting fund's unencumbered cash................................... 

34. Total number of open positions (approximate), determined on the 

basis of each position and not the issuer or counterparty ................... 

1st

Month

2nd 

Month

3rd 

Month
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 22 of 53

35. For each open position of the reporting fund that represents 5% or more of the reporting fund's net 

asset value, provide the information requested below.

(a) First month of the reporting period

(i) Position ...................................................... 

(ii) Position ...................................................... 

(b) Second month of the reporting period

(i) Position ...................................................... 

(ii) Position ...................................................... 

(c) Third month of the reporting period

(i) Position ...................................................... [drop-down of asset classes]

(ii) Position ...................................................... [drop-down of asset classes]

36. For each of the top five counterparties listed in your response to Question 22 with respect to the reporting

fund, provide the following information regarding the collateral and other credit support that the 

counterparty has posted to the reporting fund. 

(For purposes of Questions 36, 37 and 38, include as collateral assets purchased in connection with repos 

and collateral posted under an arrangement pursuant to which the secured party has loaned securities to 

the pledgor. Repos and reverse-repos with the same counterparty may be netted to the extent secured by 

the same type of collateral.)

(a) Counterparty [1, 2, 3, 4, 5]:

(i) value of collateral posted in the form of cash and cash equivalents .....

(ii) value of collateral posted in the form of securities (other than cash and 

cash equivalent instruments)..................................................................

(iii) value of other collateral and credit support posted (including face

amount of letters of credit and similar third party credit support).........

37. For each of the top five counterparties listed in your response to Question 23 with respect to the reporting

fund, provide the following information regarding the collateral and other credit support that the reporting

fund has posted to the counterparty.

(a) Counterparty [1, 2, 3, 4, 5]:

(i) value of collateral posted in the form of cash and cash equivalents .....

(ii) value of collateral posted in the form of securities (other than cash and 

cash equivalent instruments)..................................................................

(iii) value of other collateral and credit support posted (including face

amount of letters of credit and similar third party credit support).........

38. (a) Of the total amount of collateral and other credit support that counterparties have posted to the 

reporting fund, what percentage:

(i) may be rehypothecated?

(ii) has the reporting fund rehypothecated?

(b) Of the total amount of collateral and other credit support that the reporting

fund has posted to counterparties, what percentage may be rehypothecated?

% of net asset value Sub-asset class

[drop-down of asset classes]

[drop-down of asset classes]

[drop-down of asset classes]

[drop-down of asset classes]
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 23 of 53

39. During the reporting period, did the reporting fund clear any transactions directly through a 

CCP? 

Yes No

Item C. Reporting fund risk metrics

40. (a) During the reporting period, did you regularly calculate the VaR of the reporting fund? 

(Please respond without regard to whether you reported the result of this

calculation internally or to investors.)

Yes No

(b) If you responded “yes” to Question 40(a), provide the following information.

(If you regularly calculate the VaR of the reporting fund using multiple combinations

of confidence interval, horizon and historical observation period, complete a 

separate response to this Question 40(b) for each such combination.)

(i) Confidence interval used (e.g., 100%-alpha%) (as a percentage) ..........

(ii) Time horizon used (in number of days)...................................................

(iii) What weighting method was used to calculate VaR? 

None Exponential Other: ____________ 

(iv) If you responded “exponential” to Question 40(b)(iii), provide the 

weighting factor used (as a decimal to two places)..............................

(v) What method was used to calculate VaR? 

Historical simulation Monte Carlo simulation

Parametric Other: 

(vi) Historical lookback period used (in number of years; enter “NA” if

none used)................................................................................................ 

(vii) VaR at the end of the 1st month of the reporting period

(as a % of NAV).......................................................................................

(viii) VaR at the end of the 2nd month of the reporting period

(as a % of NAV).......................................................................................

(ix) VaR at the end of the 3rd month of the reporting period

(as a % of NAV).......................................................................................

41. Are there any risk metrics other than (or in addition to) VaR that you consider to be 

important to the reporting fund's risk management?

(Select all that you consider relevant. Please respond without regard to whether you

reported the metric internally or to investors. If none, “None.”)

[drop-down of risk metrics] 

Other: _______________ 
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 24 of 53

42. For each of the market factors identified below, determine the effect of the specified

changes on the reporting fund's portfolio and provide the results. 

(You may omit a response to any market factor that you do not regularly consider in formal

testing in connection with the reporting fund’s risk management. If you omit any market

factor, check either the box in the first column indicating that you believe that this market 

factor is not relevant to the reporting fund’s portfolio or the box in the second column

indicating that this market factor is relevant but not formally tested. For this purpose,

“formal testing” means that the adviser has models or other systems capable of simulating 

the effect of a market factor on the fund's portfolio, not that the specific assumptions outlined 

in the question were used in testing.) 

(For each market factor, separate the effect on your portfolio into long and short components 

where (i) the long component represents the aggregate result of all positions whose valuation 

changes in the same direction as the market factor under a given stress scenario and (ii) the 

short component represents the aggregate result of all positions whose valuation changes in 

the opposite direction from the market factor under a given stress scenario.) 

(Assume that changes in a market factor occur instantaneously and that all other factors are

held constant. If the specified change in any market factor would make that factor less than

zero, use zero instead.)

(Please note the following regarding the market factors identified below:

(i) A change in “equity prices” means that the prices of all equities move up or down by the

specified amount, without regard to whether the equities are listed on any exchange or 

included in any index;

(ii) “Risk free interest rates” means rates of interest accruing on sovereign bonds issued by 

governments having the highest credit quality, such as U.S. treasury securities;

(iii) A change in “credit spreads” means that all spreads against risk free interest rates

change by the specified amount;

(iv) A change in “currency rates” means that the values of all currencies move up or down by the 

specified amount relative to the reporting fund’s base currency;

(v) A change in “commodity prices” means that the prices of all physical commodities move up 

or down by the specified amount;

(vi) A change in “option implied volatilities” means that the implied volatilities of all the

options that the reporting fund holds increase or decrease by the specified number of 

percentage points; and

(vii) A change in “default rates” means that the rate at which debtors default on all instruments of the 

specified type increases or decreases by the specified number of percentage points.)
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 25 of 53

Not relevantRelevant/not

formally tested

Market factor – changes in market factor

Effect on 

long 

components

of portfolio

(as % of

NAV)

Effect on 

short 

components

of portfolio

(as % of

NAV)

Equity prices:

Equity prices increase 5%.........................................

Equity prices decrease 5% ........................................

Equity prices increase 20%.......................................

Equity prices decrease 20% ......................................

Risk free interest rates (changes represent a parallel shift in the yield curve):

Risk free interest rates increase 25bp........................

Risk free interest rates decrease 25bp .......................

Risk free interest rates increase 75bp........................

Risk free interest rates decrease 75bp .......................

Credit spreads:

Credit spreads increase 50bp.....................................

Credit spreads decrease 50bp....................................

Credit spreads increase 250bp...................................

Credit spreads decrease 250bp ..................................

Currency rates:

Currency rates increase 5%.......................................

Currency rates decrease 5% ......................................

Currency rates increase 20%.....................................

Currency rates decrease 20% ....................................

Commodity prices:

Commodity prices increase 10%...............................

Commodity prices decrease 10% ..............................

Commodity prices increase 40%...............................

Commodity prices decrease 40% ..............................
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 26 of 53

Option implied volatilities:

Implied volatilities increase 4 percentage points ......

Implied volatilities decrease 4 percentage points......

Implied volatilities increase 10 percentage points ....

Implied volatilities decrease 10 percentage points....

Default rates (ABS):

Default rates increase 1 percentage point..................

Default rates decrease 1 percentage point.................

Default rates increase 5 percentage points................

Default rates decrease 5 percentage points ...............

Default rates (corporate bonds and CDS):

Default rates increase 1 percentage point..................

Default rates decrease 1 percentage point.................

Default rates increase 5 percentage points ................

Default rates decrease 5 percentage points ...............

Item D. Financing information

43. For each month of the reporting period, provide the following information regarding the value of 

the reporting fund's borrowings, the types of creditors and the collateral posted to secure its 

borrowings. 

(For each type of borrowing, information is requested regarding the percentage borrowed from 

specified types of creditors. In each case, the total percentages allocated among these types of

creditors should add up to 100%.)

(Do not net out amounts that the reporting fund loans to creditors or the value of collateral pledged

to creditors.)

(a) Dollar amount of unsecured borrowing ..................................... 

(i) Percentage borrowed from U.S. financial institutions....... 

(ii) Percentage borrowed from non-U.S. financial 

institutions ......................................................................... 

(iii) Percentage borrowed from U.S. creditors that are not

financial institutions ........................................................ 

(iv) Percentage borrowed from non-U.S. creditors that are not 

financial institutions ........................................................

1st 

Month

2nd 

Month

3rd 

Month
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 27 of 53

(b) Secured borrowing.

(Classify secured borrowing according to the legal agreement governing the borrowing (e.g.,

Global Master Repurchase Agreement for reverse repo and Prime Brokerage Agreement for

prime brokerage). Please note that for reverse repo borrowings, the amount should be the

net amount of cash borrowed (after taking into account any initial margin/independent 

amount, 'haircut' and repayments). Positions under a Global Master Repurchase Agreement 

should not be netted.)

(i) Dollar amount via prime brokerage...................................

(A) value of collateral posted in the form of cash and 

cash equivalents........................................................ 

(B) value of collateral posted in the form of securities

(other than cash and cash equivalent instruments) ... 

(C) value of other collateral and credit support posted

(including face amount of letters of credit and

similar third party credit support) ............................. 

(D) percentage borrowed from U.S. financial

institutions................................................................. 

(E) percentage borrowed from non-U.S. financial

institutions................................................................. 

(F) percentage borrowed from U.S. creditors that are not

financial institutions .................................................. 

(G) percentage borrowed from non-U.S. creditors that

are not financial institutions ...................................... 

(ii) Dollar amount via reverse repo (for purposes of items (A)

through (D) below, include as collateral any assets sold

in connection with the reverse repo as well as any

variation margin) .............................................................. 

(A) value of collateral posted in the form of cash and 

cash equivalents........................................................ 

(B) value of collateral posted in the form of securities

(other than cash and cash equivalent instruments) ... 

(C) value of other collateral and credit support posted

(including face amount of letters of credit and

similar third party credit support) ............................. 

(D) percentage borrowed from U.S. financial

institutions................................................................. 

(E) percentage borrowed from non-U.S. financial

institutions................................................................. 

(F) percentage borrowed from U.S. creditors that are not

financial institutions .................................................. 

(G) percentage borrowed from non-U.S. creditors that

are not financial institutions ...................................... 
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 28 of 53

(iii) Dollar amount of other secured borrowings..................... 

(A) value of collateral posted in the form of cash and 

cash equivalents........................................................ 

(B) value of collateral posted in the form of securities

(other than cash and cash equivalent instruments) ... 

(C) value of other collateral and credit support posted

(including face amount of letters of credit and

similar third party credit support) ............................. 

(D) percentage borrowed from U.S. financial

institutions................................................................. 

(E) percentage borrowed from non-U.S. financial 

institutions................................................................. 

(F) percentage borrowed from U.S. creditors that are not

financial institutions .................................................. 

(G) percentage borrowed from non-U.S. creditors that

are not financial institutions ...................................... 

44. For each month of the reporting period, provide the aggregate value

of all derivatives positions of the reporting fund (enter “NA” if no

outstanding derivatives positions at the end of the relevant period)....

45. For each month of the reporting period, provide the following information regarding the 

reporting fund's derivative positions that were not cleared by a CCP and the collateral posted to

secure those positions.

(If the reporting fund is a net receiver of collateral, provide the collateral value as a negative

number.)

(a) Aggregate net mark-to-market value of all derivatives

positions of the reporting fund that were not cleared by a CCP 

(enter “NA” if no relevant derivatives positions outstanding at

the end of the relevant period)................................................. 

(b) Net value of collateral posted by or to the reporting fund in

respect of these positions in the form of cash and cash

equivalents ............................................................................... 

(c) Net value of collateral posted by or to the reporting fund in

respect of these positions in the form of securities (other than

cash and cash equivalent instruments) .................................. 

(d) Net value of other collateral and credit support posted by or 

to the reporting fund in respect of these positions

(including face amount of letters of credit and similar third

party credit support................................................................ 

1st

Month

2nd 

Month

3rd 

Month

1st 

Month

2nd 

Month

3rd 

Month
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 29 of 53

46. Financing liquidity:

(a) Provide the aggregate dollar amount of borrowing by and cash

financing available to the reporting fund (including all drawn and 

undrawn, committed and uncommitted lines of credit as well as any

term financing)......................................................................................

(b) Divide the amount reported in response to Question 46(a) among the periods

specified below depending on the longest period for which the creditor is contractually

committed to provide such financing.

(If a creditor (or syndicate or administrative/collateral agent) is permitted to vary unilaterally

the economic terms of the financing or to revalue posted collateral in its own discretion and 

demand additional collateral, then the financing should be deemed uncommitted for purposes

of this question. Uncommitted financing should be included under “1 day or less.”)

(The total should add up to 100%.)

% of total

financing

1 day or less ......................................................................................... 

2 days – 7 days.....................................................................................

8 days – 30 days .................................................................................. 

31 days – 90 days ................................................................................ 

91 days – 180 days .............................................................................. 

181 days – 365 days............................................................................. 

Longer than 365 days........................................................................... 

47. Identify each creditor, if any, to which the reporting fund owed an amount in respect of

borrowings equal to or greater than 5% of the reporting fund’s net asset value as of the data 

reporting date. For each such creditor, provide the amount owed to that creditor.

(This question does not require the precise legal name of the creditor; if the creditor

belongs to an affiliated group that is included in the list below, select that group and do not

enter the creditor’sname in the space for “other.”)

Name of creditor

Dollar amount

owed to

each creditor

[drop-down list of creditor/counterparty names]

Other: _____________________ 

[repeat drop-down list of creditor/counterparty names]

Other: _____________________ 

[repeat drop-down list of creditor/counterparty names]

Other: _____________________ 
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 30 of 53

Item E. Investor information

48. (a) As of the data reporting date, what percentage of the reporting fund's 

net asset value, if any, is subject to a “side-pocket” arrangement?

(This question relates to whether assets are currently in a side-pocket and not the potential for 

assets to be moved to a side-pocket.) 

(b) Have additional assets been placed in a side-pocket since the end of the prior reporting 

period?

(Check “NA” if you reported no assets under Question 48(a) in the current period

and/or the prior period.)

Yes No NA

49. Provide the following information regarding the reporting fund's restrictions on investor 

withdrawals and redemptions.

(For Questions 49 and 50, please note that the standards for imposing suspensions and restrictions

on withdrawals/redemptions may vary among funds. Make a good faith determination of the

provisions that would likely be triggered during conditions that you view as significant market

stress.)

(a) Does the reporting fund provide investors with withdrawal/redemption rights in the 

ordinary course?

Yes No

(If you responded “yes” to Question 49(a), then you must respond to Questions 49(b)-(e).)

As of the data reporting date, what percentage of the reporting fund’s net asset value, if 

any:

(b) May be subjected to a suspension of investor withdrawals/redemptions by 

an adviser or fund governing body (this question relates to an adviser's or

governing body's right to suspend and not just whether a suspension is 

currently effective)........................................................................................

(c) May be subjected to material restrictions on investor withdrawals/

redemptions (e.g., “gates”) by an adviser or fund governing body (this 

question relates to an adviser's or governing body's right to impose a 

restriction and not just whether a restriction has been imposed) ................

(d) Is subject to a suspension of investor withdrawals/redemptions (this

question relates to whether a suspension is currently effective and not just

an adviser's or governing body's right to suspend) .....................................

(e) Is subject to a material restriction on investor withdrawals/redemptions

(e.g., a “gate”) (this question relates to whether a restriction has been 

imposed and not just an adviser's or governing body's right to impose a 

restriction)....................................................................................................
Form PF

Section 2b

Information about qualifying hedge funds that you advise

(to be completed by large private fund advisers only) 

Page 31 of 53

50. Investor liquidity (as a % of net asset value):

(Divide the reporting fund’s net asset value among the periods specified below depending on

the shortest period within which investors are entitled, under the fund documents, to withdraw 

invested funds or receive redemption payments, as applicable. Assume that you would impose

gates where applicable but that you would not completely suspend withdrawals/redemptions

and that there are no redemption fees. Please base on the notice period before the valuation

date rather than the date proceeds would be paid to investors.)

(The total should add up to approximately 100%.)

% of NAV locked for

1 day or less ........................................................................ 

2 days – 7 days....................................................................

8 days – 30 days ................................................................. 

31 days – 90 days ............................................................... 

91 days – 180 days ............................................................. 

181 days – 365 days............................................................ 

Longer than 365 days.......................................................... 
Form PF

Section 3

Information about liquidity funds that you advise

(to be completed by large private fund advisers only) 

Page 32 of 53

Section 3: Information about liquidity funds that you advise.

You must complete a separate Section 3 for each liquidity fund that you advise. However, with respect

to master-feeder arrangements and parallel fund structures, you may report collectively or separately

about the component funds as provided in the General Instructions.

Item A. Reporting fund identifying and operational information

51. (a) Name of the reporting fund ............................................................................

(b) Private fund identification number of the reporting fund ..............................

52. Does the reporting fund use the amortized cost method of valuation in computing its

net asset value? 

Yes No

53. Does the reporting fund use the penny rounding method of pricing in computing its net 

asset value? 

Yes No

54. (a) Does the reporting fund have a policy of complying with the risk limiting conditions

of rule 2a-7? 

Yes No

(b) If you responded “no” to Question 54(a) above, does the reporting fund have a 

policy of complying with the following provisions of rule 2a-7: 

(i) the diversification conditions? Yes No

(ii) the credit quality conditions? Yes No

(iii)the liquidity conditions? Yes No

(iv) the maturity conditions? Yes No

Item B. Reporting fund assets

55. Provide the following information for each month of the reporting period. 

1st

Month

2nd

Month

3rd

Month

(a) Net asset value of reporting fund as reported to current and 

prospective investors

(b) Net asset value per share of reporting fund as reported to current 

and prospective investors (to the nearest hundredth of a cent)

(c) Net asset value per share of reporting fund (to the nearest 

hundredth of a cent; exclude the value of any capital support 

agreement or similar arrangement)

(d) WAM of reporting fund (in days)
Form PF

Section 3

Information about liquidity funds that you advise

(to be completed by large private fund advisers only) 

Page 33 of 53

(e) WAL of reporting fund (in days)

(f) 7-day gross yield of reporting fund (to the nearest hundredth

of one percent

(g) Dollar amount of the reporting fund's assets that are daily liquid

assets

(h) Dollar amount of the reporting fund's assets that are weekly 

liquid assets

(i) Dollar amount of the reporting fund's assets that have a 

maturity greater than 397 days

Item C. Financing information

56. (a) Is the amount of total borrowing reported in response to Question 12 equal to or greater than 

5% of the reporting fund's net asset value? 

Yes No

(b) If you responded “yes” to Question 56(a) above, divide the dollar amount of total borrowing

reported in response to Question 12 among the periods specified below depending on the type

of borrowing, the type of creditor and the latest date on which the reporting fund may repay

the principal amount of the borrowing without defaulting or incurring penalties or additional

fees.

(If a creditor (or syndicate or administrative/collateral agent) is permitted to vary unilaterally

the economic terms of the financing or to revalue posted collateral in its own discretion and 

demand additional collateral, then the borrowing should be deemed to have a maturity of 1 

day or less for purposes of this question. For amortizing loans, each amortization payment

should be treated separately and grouped with other borrowings based on its payment date.)

(The total amount of borrowings reported below should equal approximately the total amount

of borrowing reported in response to Question 12.) 

(i) Unsecured borrowing

1 day or 

less

2 days to 7 

days 

8 days to 30 

days 

31 days to 

397 days 

Greater 

than 397 

days 

(A) U.S. financial institutions

(B) Non-U.S. financial institutions 

(C) Other U.S. creditors 

(D) Other non-U.S. creditors

(ii) Secured borrowing

(A) U.S. financial institutions
Form PF

Section 3

Information about liquidity funds that you advise

(to be completed by large private fund advisers only) 

Page 34 of 53

57. (a) Does the reporting fund have in place one or more committed liquidity facilities?

Yes No

(b) If you responded “yes” to Question 57(a), provide the aggregate

dollar amount of commitments under the liquidity facilities

Item D. Investor information

58. Specify the number of outstanding shares or units of the reporting fund's 

stock or similar securities...................................................................

59. Provide the following information regarding investor concentration.

(For purposes of this question, if you know that two or more beneficial owners of the reporting fund 

are affiliated with each other, you should treat them as a single beneficial owner.)

(a) Specify the percentage of the reporting fund's equity that is 

beneficially owned by the beneficial owner having the largest equity

interest in the reporting fund.....................................................

(b) How many investors beneficially own 5% or more of the reporting fund's 

equity? ..........................................................................................

60. Provide a good faith estimate, as of the data reporting date, of the 

percentage of the reporting fund's outstanding equity that was purchased 

using securities lending collateral................................................................

61. Provide the following information regarding the restrictions on withdrawals

and redemptions by investors in the reporting fund. 

(For Questions 61 and 62, please note that the standards for imposing suspensions and restrictions

on withdrawals/redemptions may vary among funds. Make a good faith determination of the

provisions that would likely be triggered during conditions that you view as significant market

stress.)

As of the data reporting date, what percentage of the reporting fund's net asset value, 

if any:

(a) May be subjected to a suspension of investor withdrawals/redemptions

by an adviser or fund governing body (this question relates to an 

adviser's or governing body's right to suspend and not just whether a 

suspension is currently effective)................................................

(b) May be subjected to material restrictions on investor withdrawals/

redemptions (e.g., “gates”) by an adviser or fund governing body (this 

question relates to an adviser's or governing body's right to impose a 

restriction and not just whether a restriction been imposed) ...............

(B) Non-U.S. financial institutions 

(C) Other U.S. creditors 

(D) Other non-U.S. creditors
Form PF

Section 3

Information about liquidity funds that you advise

(to be completed by large private fund advisers only) 

Page 35 of 53

(c) Is subject to a suspension of investor withdrawals/redemptions (this

question relates to whether a suspension is currently effective and not

just an adviser's or governing body's right to suspend). ...............

(d) Is subject to a material restriction on investor withdrawals/redemptions

(e.g., a “gate”) (this question relates to whether a restriction has been 

imposed and not just an adviser's or governing body's right to impose 

a restriction). ................................................................

62. Investor liquidity (as a % of net asset value):

(Divide the reporting fund’s net asset value among the periods specified below depending on

the shortest period within which investors are entitled, under the fund documents, to

withdraw invested funds or receive redemption payments, as applicable. Assume that you

would impose gates where applicable but that you would not completely suspend

withdrawals/redemptions and that there are no redemption fees. Please base on the notice

period before the valuation date rather than the date proceeds would be paid to investors.

The total should add up to 100%.)

1 day or less ......................................................................... 

2 days – 7 days..................................................................... 

8 days – 30 days .................................................................. 

31 days – 90 days ................................................................ 

91 days – 180 days .............................................................. 

181 days – 365 days............................................................. 

Longer than 365 days........................................................... 

% of NAV locked for
Form PF

Section 3

Information about liquidity funds that you advise

(to be completed by large private fund advisers only) 

Page 36 of 53

Item E. Portfolio Information

63. For each security held by the reporting fund, provide the following information

for each month of the reporting period. 

(a) Name of the issuer .....................................................................................

(b) Title of the issue (including coupon, if applicable)..................................... 

(c) CUSIP...........................................................................................................

(d) LEI, if available........................................................................................

(e) In addition to CUSIP and LEI, provide at least one of the following other

identifiers, if available:

(i) ISIN...................................................................................................

(ii) CIK...................................................................................................

(iii) Other unique identifier....................................................................

(f) The category of investment that most closely identifies the instrument 

(Select from among the following categories of investment: U.S. Treasury 

Debt; U.S. Government Agency Debt; Non-U.S. Sovereign, Sub-Sovereign 

and Supra-National debt; Certificate of Deposit; Non- Negotiable Time 

Deposit; Variable Rate Demand Note; Other Municipal Security; Asset 

Backed Commercial Paper; Other Asset Backed Securities; U.S. Treasury 

Repurchase Agreement, if collateralized only by U.S. Treasuries (including 

Strips) and cash; U.S. Government Agency Repurchase Agreement, 

collateralized only by U.S. Government Agency securities, U.S. Treasuries, 

and cash; Other Repurchase Agreement, if any collateral falls outside 

Treasury, Government Agency and cash; Insurance Company Funding 

Agreement; Investment Company; Financial Company Commercial Paper; 

Non-Financial Company Commercial Paper; or Tender Option Bond. If 

Other Instrument, include a brief description.) 

(g) For repos, specify whether the repo is “open” (i.e., the repo has no specified

end date and, by its terms, will be extended or “rolled” each business day 

(or at another specified period) unless the investor chooses to terminate it),

and provide the following information about the securities subject to the

repo (i.e., the collateral):

(If multiple securities of an issuer are subject to the repo, the securities 

may be aggregated, in which case provide: (i) the total principal amount 

and value and (ii) the range of maturity dates and interest rates.)

(i) Whether the repo is “open” .................................................. 

(ii) Name of the collateral issuer ............................................................ 

(iii) CUSIP...............................................................................................

(iv) LEI, if available.....................................................................................
Form PF

Section 3

Information about liquidity funds that you advise

(to be completed by large private fund advisers only) 

Page 37 of 53

(v) Maturity date ....................................................................................

(vi) Coupon or yield ................................................................................

(vii) The principal amount, to the nearest cent.........................................

(viii) Value of the collateral, to the nearest cent........................................

(ix) The category of investment that most closely represents the 

collateral ..........................................................................................

(Select from among the following categories of investment: AssetBacked Securities; Agency Collateralized Mortgage Obligations; 

Agency Debentures and Agency Strips; Agency Mortgage-Backed 

Securities; Private Label Collateralized Mortgage Obligations; 

Corporate Debt Securities; Equities; Money Market; U.S. Treasuries 

(including strips); Other Instrument. If Other Instrument, include a 

brief description, including, if applicable, whether it is a collateralized 

debt obligation, municipal debt, whole loan, or international debt).

(h) If the rating assigned by a credit rating agency played a substantial role in

the reporting fund’s (or its adviser’s) evaluation of the quality, maturity or

liquidity of the security, provide the name of each credit rating agency and

the rating each assigned to the security.

(i) The maturity date used to calculate WAM..................................................... 

(j) The maturity date used to calculate WAL......................................................

(k) The ultimate legal maturity date (i.e., the date on which, in accordance with

the terms of the security without regard to any interest rate readjustment or 

demand feature, the principal amount must unconditionally be paid)...........

(l) If the security has a demand feature on which the reporting fund (or its

adviser) is relying when evaluating the quality, maturity, or liquidity of the 

security, provide the following information:

(If the security does not have such a demand feature, enter “NA.”)

(i) Identity of the demand feature issuer(s) ...........................................

(ii) If the rating assigned by a credit rating agency played a substantial

role in the reporting fund’s (or its adviser’s) evaluation of the quality,

maturity or liquidity of the demand feature, its issuer, or the security

to which it relates, provide the name of each credit rating agency and

the rating assigned by each credit rating agency .................................

(iii) The period remaining until the principal amount of the security may

be recovered through the demand feature...........................................

(iv) The amount (i.e., percentage) of fractional support provided by each 

demand feature issuer...........................................................................

(v) Whether the demand feature is a conditional demand feature...........

(m) If the security has a guarantee (other than an unconditional letter of credit

reported in response to Question 63(l) above) on which the reporting fund
Form PF

Section 3

Information about liquidity funds that you advise

(to be completed by large private fund advisers only) 

Page 38 of 53

(or its adviser) is relying when evaluating the quality, maturity, or liquidity

of the security, provide the following information:

(If the security does not have such a guarantee, enter "NA.")

(i) Identity of the guarantor(s) .............................................................. 

(ii) If the rating assigned by a credit rating agency played a substantial

role in the reporting fund’s (or its adviser’s) evaluation of the 

quality, maturity or liquidity of the guarantee, the guarantor, or the

security to which the guarantee relates, provide the name of each

credit rating agency and the rating assigned by each credit rating

agency..............................................................................................

(iii) The amount (i.e., percentage) of fractional support provided by each 

guarantor............................................................................................... 

(n) If the security has any enhancements, other than those identified in response

to Questions 63(l) and (m) above, on which the reporting fund (or its

adviser) is relying when evaluating the quality, maturity, or liquidity of the 

security, provide the following information:

(If the security does not have such an enhancement, enter “NA.”)

(i) Identity of the enhancement provider(s) .......................................... 

(ii) The type of enhancement(s) ............................................................. 

(iii) If the rating assigned by a credit rating agency played a substantial

role in the reporting fund’s (or its adviser’s) evaluation of the 

quality, maturity or liquidity of the enhancement, its provider, or the

security to which it relates, provide the name of each credit rating

agency used and the rating assigned by the credit rating agency.....

(iv) The amount (i.e., percentage) of fractional support provided by each 

enhancement provider .........................................................................

(o) The yield of the security as of the reporting date:................................ 

(p) The total value of the reporting fund’s position in the security, and

separately, if the reporting fund uses the amortized cost method of

valuation, the amortized cost value, in both cases to the nearest cent:

(i) Including the value of any sponsor support...........................................

(ii) Excluding the value of any sponsor support..........................................

(q) The percentage of the reporting fund’s net assets invested in the security,

to the nearest hundredth of a percent.............................................................. 

(r) Is the security categorized as a level 3 asset or liability in Question 14?.......

(s) Is the security a daily liquid asset?..................................................................

(t) Is the security a weekly liquid asset?................................................................

(u) Is the security an illiquid security?...................................................................

(v) Explanatory notes. Disclose any other information that may be material
Form PF

Section 3

Information about liquidity funds that you advise

(to be completed by large private fund advisers only) 

Page 39 of 53

to other disclosures related to the portfolio security. 

(If none, leave blank.)

Item F. Parallel Money Market Funds

64. If the reporting fund pursues substantially the same investment objective and

strategy and invests side by side in substantially the same positions as a money

market fund advised by you or any of your related persons, provide the money

market fund’s EDGAR series identifier. ...........................................................

(If neither you nor any of your related persons advise such a money market fund, 

enter “NA.”)
Form PF

Section 4

Information about private equity funds that you advise

(to be completed by large private equity fund advisers only) 

Page 40 of 53

You must complete a separate Section 4 for each private equity fund that you advise. However, with respect

to master-feeder arrangements and parallel fund structures, you may report collectively or separately

about the component funds as provided in the General Instructions.

Item A. Reporting fund identifying information

65. (a) Name of the reporting fund.............................................................................

(b) Private fund identification number of the reporting fund ...............................

Item B. Certain information regarding the reporting fund

66. Indicate the investment strategy in the drop-down menu that best describe the reporting fund’s investment 

strategy by percent of deployed capital, during the reporting period. If the reporting fund engages in more 

than one strategy, provide a good faith estimate of the percentage of the reporting fund’s deployed capital

represented by each strategy.

(Select the investment strategy or strategies that best describe the reporting fund’s strategies, even if the 

categories below do not precisely match your characterization of the reporting fund’s strategy. If you 

report all or part of the reporting fund’s strategy as “Other”, explain in Question 83. The strategies listed 

are mutually exclusive (i.e., do not report the same portion of deployed capital in multiple strategies). The 

total should add to 100%.) 

Strategy 

% of 

capital 

[drop-down menu]

67. Identify, by ISO country code, each country to which the reporting fund’s investments in portfolio 

companies represent exposure of 10% or more of the reporting fund’s net asset value. 

(See Instruction 15 for information on calculating the numerator for purposes of this Question. You 

should categorize investments based on concentrations of risk and economic exposures.

Country ISO code % of NAV 

Section 4: Information about private equity funds that you advise.
Form PF

Section 4

Information about private equity funds that you advise

(to be completed by large private equity fund advisers only) 

Page 41 of 53

Item C. Reporting fund and portfolio company financing;

68. Provide the following information regarding the value of the reporting fund's borrowings and the

types of creditors.

(Do not net out amounts that the reporting fund loans to creditors or the value of collateral

pledged to creditors. The percentages borrowed from the specified types of creditors should

add up to approximately 100%.)

(a) Dollar amount of total borrowings............................................................................ 

(b) Percentage borrowed from U.S. financial institutions.............................................. 

(c) Percentage borrowed from non-U.S. financial institutions.......................................

(d) Percentage borrowed from U.S. creditors that are not financial institutions ............

(e) Percentage borrowed from non-U.S. creditors that are not financial institutions.....

(f) Does the reporting fund borrow or have the ability to borrow at the fund-level as an alternative or 

complement to financing of portfolio companies? If so, check “yes’ and complete subsection (g) of 

this question. Otherwise, check “no’ 

Yes No

(g) For each type of borrowing or other cash financing available to the reporting fund, provide the total 

dollar amount available and the average amount borrowed over the reporting period.

Type of Financing

Total 

amount 

available (in 

dollars) 

Average 

borrowed over 

the reporting 

period (in 

dollars)

□ Credit secured by the investments of the reporting fund 

□ Credit secured by unfunded commitments

□ Credit secured by a combination of unfunded commitments and 

investments of the reporting fund. 

□ Other (explain in Question 83) 

69. (a) Do you or any of your related persons guarantee, or are you or any of your related persons 

otherwise obligated to satisfy, the obligations of any portfolio company in which the reporting fund

invests?

(You are not required to respond “yes” simply because a portfolio company is a primary obligor

and is also your related person.)

Yes No

(b) If you responded “yes” to Question 69(a) above, report the total dollar value

of all such guarantees and other obligations....................................................

70. What is the weighted average debt-to-equity ratio of the controlled portfolio

companies in which the reporting fund invests (expressed as a decimal to the 

tenths place)? 
Form PF

Section 4

Information about private equity funds that you advise

(to be completed by large private equity fund advisers only) 

Page 42 of 53

(Weighting should be based on gross assets of each controlled portfolio company as a

percentage of the aggregate gross assets of the reporting fund’s controlled portfolio

companies.)

71. What is the highest debt-to-equity ratio of any controlled portfolio company in

which the reporting fund invests (expressed as a decimal to the tenths place)? 

72. What is the lowest debt-to-equity ratio of any controlled portfolio company in

which the reporting fund invests (expressed as a decimal to the tenths place)? 

73. What is the aggregate gross asset value of the reporting fund's controlled 

portfolio companies? 

74. What is the aggregate principal amount of borrowings categorized as current 

liabilities on the most recent balance sheets of the reporting fund's controlled 

portfolio companies? 

75. What is the aggregate principal amount of borrowings categorized as long-term 

liabilities on the most recent balance sheets of the reporting fund's controlled 

portfolio companies? 

76. What percentage of the aggregate borrowings of the reporting fund's controlled 

portfolio companies is payment-in-kind (PIK) or zero-coupon debt?

77. During the reporting period, did the reporting fund or any of its controlled portfolio

companies experience an event of default under any of its indentures, loan agreements or

other instruments evidencing obligations for borrowed money? If so, check “yes” and 

complete subsections (a) of this question. Otherwise, check “no”.

(Do not include a potential event of default (i.e., an event that would constitute an event of 

default with the giving of notice, the passage of time or otherwise) unless it has become an

event of default.)

Yes No

(a) Identify the nature of the default event (check all that apply): 

□ Payment default of the reporting fund 

□ Payment default of a controlled portfolio company

□ A default relating to a failure to uphold terms under the applicable borrowing 

agreement, other than a failure to make regularly scheduled payments.

78.(a) Does any controlled portfolio company of the reporting fund have in place one or more bridge loans

or commitments (subject to customary conditions) for a bridge loan?

Yes No

(b) If you responded “yes” to Question 78(a), identify each person that has provided all or part of any

bridge loan or commitment to the relevant controlled portfolio company. For each such person, 

provide the applicable outstanding amount or commitment amount.
Form PF

Section 4

Information about private equity funds that you advise

(to be completed by large private equity fund advisers only) 

Page 43 of 53

Legal Name of Counterparty

LEI, if 

any

Indicate below if the 

counterparty is affiliated with 

a major financial institution

Outstanding amount of

financing, if drawn

Amount of

commitment, if

undrawn

[repeat drop-down list of 

creditor/counterparty names]

Other: 

[repeat drop-down list of 

creditor/counterparty names]

Other: 

[repeat drop-down list of 

creditor/counterparty names]

Other: 

Item D: Portfolio company investment exposures

79. (a) Is any of the reporting fund's controlled portfolio companies a financial industry portfolio

company? 

Yes No

(b) If you responded “yes” to Question 79(a), then for each of the reporting fund's controlled portfolio

companies that constitutes a financial industry portfolio company, provide the following

information.

% of % of

Address of reporting portfolio

principal Debt-to- Gross fund’s gross company

office equity asset assets beneficially

(include city, ratio of value of invested in owned by the

Legal state and NAICS LEI, if portfolio portfolio this portfolio reporting

Name country) code any company company company fund

80. Provide a breakdown of the reporting fund's investments in portfolio companies by industry, based on 

the NAICS codes of the companies.

(The total should add up to 100%.)

NAICS code

% of reporting fund’s total

portfolio company investments
Form PF

Section 4

Information about private equity funds that you advise

(to be completed by large private equity fund advisers only) 

Page 44 of 53

81. If you or any of your related persons (other than the reporting fund) invest in any 

companies that are portfolio companies of the reporting fund, provide the aggregate

dollar amount of these investments.

82. If the reporting fund effectuates (i) any general partner clawback or (ii) a limited partner 

clawback or clawbacks in excess of an aggregate amount equal to 10 percent of a fund’s 

aggregate capital commitments, provide the following: 

(a) Effective date:

(b) Type of clawback (General Partner/Limited Partner):

(c) Reason for clawback:

83. You may provide any information you believe would be helpful in understanding the 

information reported in response to any question in this Section 4 of this form. Identify 

the related question for each comment (use a drop-down menu so that notes are received 

in a structured format).
Form PF

Section 5

Current report for large hedge fund advisers

to qualifying hedge funds

Page 45 of 53

Upon the occurrence of any one or more of the events specified in Items B to I of this Section 5, you must file 

a current report responding to questions required by the applicable Item(s) (a “current report”) as soon as 

practicable, but no later than 72 hours. The 72 hour period begins upon the occurrence of the event or when 

you reasonably believe the event occurred and you must respond to the best of your knowledge on the date of 

your current report. You may provide an additional explanation of the facts and circumstances relating to the 

event, including the causes and or proposed resolution in explanatory notes under Item J of this Section 5. 

In this Section 5, references to most recent net asset value mean the net asset value reported as of the data 

reporting date. 

 Check here if you are filing an amendment to a previously filed current report. Provide the filing date of 

the current report you are amending [Drop-down list of Month, Day, Year, Time]. 

Item A: Information about you and the reporting fund

5-1 Provide your name and the other identifying information requested below. 

(This should be your full legal name.) 

Legal name

CRD 

Number SEC 801-Number 

NFA ID

Number, if any 

Large trader 

ID, if any 

Large trader 

ID suffix, if any 

5-2(a) Name of the reporting fund

5-2(b) Private fund identification number of the reporting fund

5-2(c) NFA identification number of the reporting fund, if applicable 

5-2(d) LEI of the reporting fund, if any

 5-3 Signatures of authorized representative (see Instruction 11 to Form PF) 

I, the undersigned, sign this Section 5 on behalf of, and with the authority of, the firm. In addition, I sign this 

Section 5 on behalf of, and with the authority of, each of the related persons identified in Question 1(b) (other 

than any related person for which another individual has signed this Section 5 below). 

Name of individual: 

Signature: 

Title:

Email address:

Telephone contact number (include area code and, if outside the United States, 

country code): 

Date:

Signature on behalf of related persons:

I, the undersigned, sign this Section 5 on behalf of, and with the authority of, the related person(s) identified 

below. 

Name of each related person on behalf of which this individual is signing: 

Section 5: Current report for large hedge fund advisers to qualifying hedge funds. 
Form PF

Section 5

Current report for large hedge fund advisers

to qualifying hedge funds

Page 46 of 53

Name of individual: 

Signature: 

Title:

Email address:

Telephone contact number (include area code and, if outside the United States, 

country code): 

Date:

Item B. Extraordinary Investment Losses

If on any business day the 10-business-day holding period return of the reporting fund is less than or equal to -

20% of reporting fund aggregate calculated value, provide the information required by Questions 5-4 to 5-7, 

below. (Current reports should not be filed for overlapping 10-business-day periods.)

5-4 Beginning date of the 10-business-day loss period:

5-5 End date of the 10-business-day loss period:

5-6 Holding period return: 

5-7 Dollar amount of loss over the 10-business-day loss period: 

 

Item C. Margin, Collateral or Equivalent Increase

If the total dollar value of margin, collateral, or an equivalent posted by the reporting fund at the end of a 

rolling 10-business-day period less the total dollar value of margin, collateral, or an equivalent posted by the 

reporting fund at the beginning of the rolling 10-business-day period is greater than or equal to 20% of the 

average daily reporting fund aggregate calculated value during the period, provide the following information. 

(if the total value of margin, collateral or an equivalent posted by the reporting fund continues to increase, do 

not file another current report until on or after the next 10-business-day period beginning after the end date 

stated at 5-9 below.) 

5-8 Beginning date of the 10-business-day period during which 

the increase was measured:

5-9 End date of the 10-business-day period during which the 

increase was measured:

5-10 Provide the total dollar value amount of margin, collateral 

or an equivalent posted by the reporting fund at the beginning of 

the 10-business-day period during which the increase was 

measured:

5-11 Provide the total dollar value amount of margin, collateral 

or an equivalent posted by the reporting fund at the end of the 10-

business-day period during which the increase was measured:

5-12 Provide the average daily reporting fund aggregate 

calculated value of the reporting fund during the 10-business-day 

period during which the increase was measured:

5-13 Counterparty or counterparties requiring increased margin, collateral or equivalent. (If multiple 

counterparties are involved list them in order of the dollar amount of cumulative increase required by each 

counterparty.) 
Form PF

Section 5

Current report for large hedge fund advisers

to qualifying hedge funds

Page 47 of 53

Legal name of the counterparty 

Counterparty LEI, if 

any 

(a)

(b) 

(c)

5-14 Check one or more of the following to describe your current understanding of circumstances relating to 

the margin increase(s) (check all that apply): 

The increase is a result of exchange or CCP requirements or known regulatory action affecting the 

counterparty. 

A counterparty or counterparties independently increased the reporting fund’s margin, collateral or 

equivalent requirements.

The reporting fund established a new relationship or new business with one or more counterparties. 

The increase is attributable to new investment positions, investment approach or strategy and/or 

portfolio turnover of the reporting fund. 

The increase is related to a deteriorating position or positions in the reporting fund’s portfolio or other 

credit trigger under applicable counterparty agreements.

Other (provide explanation in Item J). 

Item D. Notice of Margin Default or Determination of Inability to Meet a Call for Margin, Collateral 

or Equivalents 

Provide the following information if you either (1) receive notification that the reporting fund is in default on a 

call for margin, collateral or an equivalent, resulting in a deficit that the reporting fund will not be able to 

cover or address by adding additional funds (in situations where there is a contractually agreed upon cure 

period an adviser would not be required to file an Item D current report until the expiration of the cure period 

unless the fund would not expect to be able to meet call during such cure period), provide the following 

information; or (2) if you determine that the reporting fund is unable to meet a call for increased margin, 

collateral or an equivalent, including in situations where there is a dispute regarding the amount or 

appropriateness of the margin call.

(You are not required to file a current report in situations where you dispute the amount and appropriateness 

of a call for increased margin, collateral or an equivalent, provided the reporting fund has sufficient assets to 

meet the greatest of the disputed amounts.) 

(If you make this determination for more than one counterparty on the same day, provide the information 

required by 5-15 to 5-18 for each counterparty affected.)

5-15 Date of the notification or determination: 

5-16 Dollar amount of the call for margin, collateral or equivalent: 

 5-17 Counterparty: 

Legal name of the counterparty Counterparty LEI, if any

5-18 Check one or more of the following to describe your current understanding of the circumstances relating 
Form PF

Section 5

Current report for large hedge fund advisers

to qualifying hedge funds

Page 48 of 53

to the default or your determination that the reporting fund is unable to meet a call for increased margin, 

collateral or an equivalent:

 A counterparty increased margin, collateral or equivalent requirements for the reporting fund 

contributed to the default or inability to meet a call for increased margin, collateral or an 

equivalent. 

 Losses in the value of the reporting fund’s portfolio or other credit trigger under applicable 

counterparty agreements contributed to the default or inability to meet a call for increased 

margin, collateral or an equivalent.

 A default or settlement failure of a counterparty contributed to the default or inability to meet 

a call for increased margin, collateral or an equivalent.

 Other (provide explanation in Item J). 

Item E. Counterparty Default

If a counterparty to the reporting fund (1) does not meet a call for margin, collateral or equivalent or fails to 

make any other payment, in the time and form contractually required (taking into account any contractually 

agreed cure period), and (2) the amount involved is greater than 5% of the reporting fund aggregate calculated 

value, provide the following information. 

(If you make this determination for more than one counterparty on the same day, provide the information 

required by 5-19 to 5-21 for each counterparty affected.) 

5-19 Date of default: 

5-20 Dollar amount of default: 

5-21 Counterparty: 

Legal name of the counterparty Counterparty LEI, if any 

Item F. Prime Broker Relationship Terminated or Materially Restricted

If (1) a prime broker terminates or materially restricts its relationship with the reporting fund, in whole or in 

part, in markets where that prime broker continues to be active; or (2) the relationship between the prime 

broker and the reporting fund was terminated by either the reporting fund or the prime broker in the last 72 

hours or less in accordance with the Section 5 current reporting period, and a termination event was activated 

in the prime brokerage agreement or related agreements, within the last 12 months provide the following 

information below. (Termination events, as specified in the prime broker agreement or related agreements, 

that are isolated to the financial state, activities or other conditions solely of the prime broker should not be 

considered for the purposes of this question.) 

5-22 Date of the termination or material restriction:

5-23 Date of the termination event(s) if different from date in 5-22:

 5-24 Prime Broker: 

Legal name of the prime broker Prime broker LEI, if any 

 
Form PF

Section 5

Current report for large hedge fund advisers

to qualifying hedge funds

Page 49 of 53

Note: If a prime broker changes the terms of its relationship with the reporting fund in a way that significantly 

limits the fund’s ability to operate under the terms of the original agreement, or significantly impairs the fund’s 

ability to trade, the adviser should consider it a “material restriction” that would require filing of this Item F.

Item G. Operations Event

In this Item G, an “operations event” means that the reporting fund or private fund adviser experiences a 

significant disruption or degradation of the reporting fund’s critical operations, whether as a result of an event 

at a service provider to the reporting fund, the reporting fund, or the adviser. For this purpose, “critical 

operations” means operations necessary for (i) the investment, trading, valuation, reporting, and risk 

management of the reporting fund; or (ii) the operation of the reporting fund in accordance with the Federal 

securities laws and regulations.

If there is an operations event, provide the following: 

5-25 Date of the operations event, or date on which you estimate the event first 

occurred: 

5-26 Date operations event was discovered (discovery date may be same or different 

than the date of the event reported in 5-25): 

5-27 Check one or more of the following to describe your current understanding of circumstances relating to 

the operations event (check all that apply and provide supplementary information in Item J if desired):

An operations event at a service provider to the reporting fund or the private fund adviser caused the

operations event (in whole or in part) (if applicable, provide the following information).

(a) Legal Name of Service Provider:

(b) LEI, if any: 

(c) Identify services provided by the third party (e.g., fund accounting, 

administration, sub-adviser, accounting, custodial, other): 

[drop-down 

menu]

An operations event that occurred internally at the reporting fund or reporting fund adviser or a 

related person.

An operations event that occurred related to a natural disaster or other force majeure event not 

within the control of the private fund adviser.

Other (provide explanation in Item J).

5-28 Has the adviser initiated a disaster recovery or business continuity plan relating to the operations event

and the continued operation of the adviser or the reporting fund? 

Yes No

5-29 Check one or more of the following to describe your current understanding of the impact of the 

operations event on the normal operations of reporting fund (check all that apply):

Disruption or degradation of trading of the reporting fund’s portfolio assets

Disruption or degradation of the valuation of the reporting fund’s portfolio assets

Disruption or degradation of your management of the reporting fund’s investment risk

Disruption or degradation of your ability to comply with applicable laws, rules, and regulations 

Other (provide explanation in Item J).
Form PF

Section 5

Current report for large hedge fund advisers

to qualifying hedge funds

Page 50 of 53

If technical or other difficulties resulting from the operations event prevent you from timely filing a current 

report, you may file as soon as practicable provided that you explain the technical or other difficulty that 

prevented timely filing in Item J of the current report.

Item H. Withdrawals and Redemptions

If the reporting fund receives cumulative requests for withdrawals or redemptions from the reporting fund

equal to or more than 50% of the most recent net asset value (after netting against subscriptions and other 

contributions from investors received and contractually committed), provide the following information:

5-30 Date on which the net withdrawals or redemption requests exceeded 50% of 

the most recent net asset value: 

5-31 Net value of withdrawals or redemptions paid from the reporting fund 

between the last data reporting date and the date of this current report: 

5-32 Percentage of fund’s most recent net asset value for which withdrawals or 

redemptions have been requested: 

5-33 Have you notified investors that the reporting fund will liquidate?

Yes No

Item I. Unable to Satisfy Redemptions or Suspension of Redemptions

If the reporting fund (1) is unable to pay redemption requests, or (2) has suspended redemptions and the 

suspension lasts for more than 5 consecutive business days; provide the following information:

5-34 Date on which the reporting fund was unable to pay or suspended 

redemptions: 

5-35 Percentage of fund’s most recent net asset value for which redemptions have 

been requested and not yet paid on the date of this current report: 

 5-36 Have you notified investors that the reporting fund will liquidate?

Yes No

Item J. Explanatory Notes 

You may provide any information you believe would be helpful in understanding the information reported in 

response to any Item in this Section 5 of this form. Identify the related question for each comment (use a 

drop-down menu so that notes are received in a structured format). 
Form PF

Section 6 

Quarterly report for advisers to private equity funds Page 51 of 53

Upon the occurrence of any one or more of the events specified in Items B or C of this section 6, you must file 

a quarterly report responding to questions required by the applicable Item(s) (a “private equity event report”). 

If any of the below items occur within a particular fiscal quarter for the private equity funds you advise you 

will file a section 6 quarterly report within 60 calendar days after the end of your first, second, third, and fourth

fiscal quarters. Do not file a section 6 quarterly report if a private equity reporting event did not occur during 

that fiscal quarter. It is not necessary to report the same instance of a reporting event again on future section 6 

filings. You may provide an additional explanation of the facts and circumstances relating to the event, 

including the causes and/or proposed resolution in explanatory notes under Item D of this section 6. 

 Check here if you are filing an amendment to a previously filed current report. Provide the filing date of 

the current report you are amending [Drop-down list of Month, Day, Year, Time].

Item A: Information about you and the reporting fund 

6-1 Provide the identifying information requested below. 

Full legal name CRD Number

SEC 801-

Number 

NFA ID

Number, if any 

Large trader 

ID, if any 

Large trader 

ID suffix, if any 

6-2(a) Name of the reporting fund

6-2(b) Private fund identification number of the reporting fund

6-2(c) NFA identification number of the reporting fund, if any 

6-2(d) LEI of the reporting fund, if any

 6-3 Signatures of authorized representative (see Instruction 11 to Form PF) 

I, the undersigned, sign this Section 6 on behalf of, and with the authority of, the firm. In addition, I sign this 

Section 6 on behalf of, and with the authority of, each of the related persons identified in Question 1(b) (other 

than any related person for which another individual has signed this Section 6 below). 

Name of individual: 

Signature: 

Title: 

Email address: 

Telephone contact number (include area code and, if outside the United States,

country code): 

Date: 

Signature on behalf of related persons:

I, the undersigned, sign this Section 6 on behalf of, and with the authority of, the related person(s) identified 

below. 

Name of individual: 

Signature:

Title: 

Email address: 

Telephone contact number (include area code and, if outside the United States, 

Section 6: Quarterly report for advisers to private equity funds. 
Form PF

Section 6 

Quarterly report for advisers to private equity funds Page 52 of 53

country code):

Date: 

Item B. Adviser-Led Secondary Transactions. 

If the reporting fund closed an adviser-led secondary transaction, provide the following:

6-4 Closing date of transaction: 

6-5 Description of transaction:

 Item C. General Partner Removal, Termination of the Investment Period or Termination of Fund. 

Upon receipt by the reporting fund or its adviser or affiliate of notification that fund investors have removed 

the adviser or its affiliate as the general partner or similar control person of the reporting fund, elected to 

terminate the reporting fund’s investment period, or elected to terminate the reporting fund, in each case, as 

contemplated by the reporting fund’s governing documents (each, a “removal event”) provide the following: 

6-6 Effective date of removal event: 

6-7 Description of removal event: 

Item D. Explanatory Notes 

You may provide any information you believe would be helpful in understanding the information reported in 

response to any Item in this Section 6 of this form. Identify the related question for each comment (use a 

drop-down menu so that notes are received in a structured format).
Form PF

Section 7 

Request for temporary hardship exemption

(to be completed by private fund advisers requesting exemption)

Page 53 of 53

You must complete Section 7 if you are requesting a temporary hardship exemption pursuant to SEC

rule 204(b)-1(f).

(a) For which type of Form PF filing are you requesting a temporary hardship exemption?

i. If you are not a large hedge fund adviser or large liquidity fund adviser: 

Initial filing

Annual update

Final filing

ii. If you are a large hedge fund adviser or large liquidity fund adviser: 

Initial filing

Quarterly update

Filing to transition to annual reporting

Final filing

(b) Provide the following information regarding your request for a temporary hardship exemption

(attach a separate page if additional space is needed).

i. Describe the nature and extent of the temporary technical difficulties when you attempt

to submit the filing to the Form PF filing system on the IARD:

ii. Describe the extent to which you previously have submitted documents in electronic

format with the same hardware and software that you are unable to use to submit this

filing:

iii. Describe the burden and expense of employing alternative means (e.g., a service

provider) to submit the filing in electronic format in a timely manner:

iv. Provide any other reasons that a temporary hardship exemption is warranted:

Section 7: Request for temporary hardship exemption.
Form PF: Glossary of Terms Page 1 

GLOSSARY OF TERMS

ABCP Asset backed commercial paper, including (but not limited to)

structured investment vehicles, single-seller conduits and multi-seller

conduit programs.

Do not include any positions held via CDS (these should be recorded

in the CDS category).

ABS Securities derived from the pooling and repackaging of cash flow

producing financial assets.

Adviser-led secondary 

transaction 

Any transaction initiated by the adviser or any of its related persons 

that offers private fund investors the choice to: (i) sell all or a portion 

of their interests in the private fund; or (ii) convert or exchange all or 

a portion of their interests in the private fund for interests in another 

vehicle advised by the adviser or any of its related persons.

Advisers Act U.S. Investment Advisers Act of 1940, as amended.

Affiliate With respect to any person, any other person that directly or indirectly

controls, is controlled by or is under common control with such

person. The term affiliated means that two or more persons are

affiliates. 

Agency securities Any security issued by a person controlled or supervised by and 

acting as an instrumentality of the government of the United States

pursuant to authority granted by the Congress of the United States

and guaranteed as to principal or interest by the United States.

Include bond derivatives.

Annual update An update of this Form PF with respect to any fiscal year.

Average daily reporting 

fund aggregate calculated 

value 

The average of the daily reporting fund aggregate calculated value

for the end of the business day on business days one through ten of 

the reporting period. 

Borrowings Secured borrowings and unsecured borrowings, collectively.

bp Basis points.

Cash and cash equivalents Cash (including U.S. and non-U.S. currencies), cash equivalents and 

government securities. For purposes of this definition:

• cash equivalents are: (i) bank deposits, certificates of deposit, 

bankers acceptances and similar bank instruments held for

investment purposes; (ii) the net cash surrender value of an

insurance policy; and (iii) investments in money market funds; 

and
Form PF: Glossary of Terms Page 2 

• government securities are: (i) U.S. treasury securities; (ii) agency

securities; and (iii) any certificate of deposit for any of the

foregoing.

CCP Central clearing counterparties (or central clearing houses) (for

example, CME Clearing, The Depository Trust & Clearing

Corporation, Fedwire and LCH Clearnet Limited).

CDO/CLO Collateralized debt obligations and collateralized loan obligations

(including, in each case, cash flow and synthetic) other than MBS. 

Do not include any positions held via CDS (these should be recorded

in the CDS category).

CDS Credit default swaps, including any LCDS. 

CEA U.S. Commodity Exchange Act, as amended.

CFTC U.S. Commodity Futures Trading Commission.

Combined money market 

and liquidity fund assets 

under management 

With respect to any adviser, the sum of: (i) such adviser’s liquidity

fund assets under management; and (ii) such adviser’s regulatory

assets under management that are attributable to money market funds 

that it advises.

Committed capital Any commitment pursuant to which a person is obligated to acquire

an interest in, or make capital contributions to, the private fund. 

Commodities Has the meaning provided in the CEA. Include ETFs that hold

commodities.

For questions regarding commodity derivatives, provide the value of

all exposure to commodities that you do not hold physically, whether

held synthetically or through derivatives (whether cash or physically

settled).

Commodity pool A “commodity pool,” as defined in section 1a(10) of the CEA. 

Conditional demand feature Has the meaning provided in rule 2a-7. 

Control Has the meaning provided in Form ADV. The term controlled has a 

corresponding meaning.

Controlled portfolio 

company 

With respect to any private equity fund, a portfolio company that is

controlled by the private equity fund, either alone or together with

the private equity fund’s affiliates or other persons that are, as of the

data reporting date, part of a club or consortium including the 

private equity fund. 

Convertible bonds Convertible corporate bonds (not yet converted into shares or cash).

Include bond derivatives, but do not include any positions held via

CDS (these should be recorded in the CDS category).
Form PF: Glossary of Terms Page 3 

Corporate bonds Bonds, debentures and notes, including commercial paper, issued by 

corporations and other non-governmental entities.

Do not include preferred equities. Include bond derivatives, but do 

not include any positions held via CDS (these should be recorded in 

the CDS category).

CPO A “commodity pool operator,” as defined in section 1a(11) of the

CEA. 

Credit derivatives Single name CDS, index CDS and exotic CDS. 

Credit rating agency Any nationally recognized statistical rating organizations, as that

term is defined in section 3(a)(62) of the Securities Exchange Act of 

1934 

Critical operations For purposes of responding to Sections 5, means the operations 

necessary for (i) the investment, trading, valuation, reporting, and 

risk management of the reporting fund; or (ii) the operation of the 

reporting fund in accordance with the Federal securities laws and 

regulations.

Crude oil For questions regarding crude oil derivatives, provide the value of all

exposure to crude oil that you do not hold physically, whether held

synthetically or through derivatives (whether cash or physically

settled).

CTA A “commodity trading advisor,” as defined in section 1a(12) of the 

CEA. 

Current report A current report provided pursuant to the items listed in Section 5 of 

Form PF.

Current reporting event Any event that triggers the requirement to complete and file a current 

report pursuant to the items in Section 5 of Form PF.

Daily liquid assets Has the meaning provided in rule 2a-7. 

Daily rate-of-return Is the percentage change in the reporting fund aggregate value from 

one day to the next and adjusted for subscriptions and redemptions, if 

necessary.

Data reporting date In the case of an initial filing, the data reporting date is the last

calendar day of your most recently completed fiscal year (or, if you

are a large hedge fund adviser or large liquidity fund adviser, your

most recently completed fiscal quarter).

In the case of an annual update, the data reporting date is the last

calendar day of your most recently completed fiscal year.

In the case of a quarterly update, the data reporting date is the last

calendar day of your most recently completed fiscal quarter.
Form PF: Glossary of Terms Page 4

Demand feature Has the meaning provided in rule 2a-7.

Dependent parallel

managed account

With respect to any private fund, any related parallel managed

account other than a parallel managed account that individually (or

together with other parallel managed accounts that pursue

substantially the same investment objective and strategy and invest

side by side in substantially the same positions) has a gross asset

value greater than the gross asset value of such private fund (or, if

such private fund is a parallel fund, the gross asset value of the 

parallel fund structure of which it is a part).

Derivative exposures

to unlisted equities

All synthetic or derivative exposures to equities, including preferred

equities, that are not listed on a regulated exchange. Include single

stock futures, equity index futures, dividend swaps, total return

swaps (contracts for difference), warrants and rights.

Dollar amount of loss over 

the 10-business-day period

Is equal to the reporting fund aggregate value at the end of the 10-

business-day loss period less the reporting fund aggregate value at 

the beginning of the 10-business day loss period less the net of any 

subscriptions or redemptions during the 10-business-day period.

EEA The European Economic Area. As of the effective date of this Form

PF, the EEA is comprised of: (i) the European Union member states,

which are Austria, Belgium, Bulgaria, Cyprus, the Czech Republic,

Denmark, Estonia, Finland, France, Germany, Greece, Hungary,

Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the

Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, 

and Sweden; and (ii) Iceland, Liechtenstein, Norway, and the United 

Kingdom.

ETF Exchange-traded fund. 

Exempt reporting

adviser

Has the meaning provided in Form ADV. 

Exotic CDS CDSs referencing bespoke baskets or tranches of CDOs, CLOs and 

other structured investment vehicles, including credit default

tranches.

Feeder fund See master-feeder arrangement. 

Financial industry

portfolio company

Any of the following: (i) a nonbank financial company, as defined in 

the Financial Stability Act of 2010; or (ii) any bank, savings

association, bank holding company, financial holding company,

savings and loan holding company, credit union or other similar

company regulated by a Federal, state, or foreign banking regulator,

including the Federal Deposit Insurance Corporation, the Board of

Governors of the Federal Reserve System, the Office of the 

Comptroller of the Currency, the National Credit Union

Administration or the Farm Credit Administration.

Firm The private fund adviser completing or amending this Form PF.
Form PF: Glossary of Terms Page 5 

Foreign exchange

derivative

Any derivative whose underlying asset is a currency other than U.S.

dollars or is an exchange rate. Cross-currency interest rate swaps

should be included in foreign exchange derivatives and excluded

from interest rate derivatives. 

Only one currency side of every transaction should be counted.

Form ADV Form ADV, as promulgated and amended by the SEC. 

Form ADV Section 7.B.1 Section 7.B.1 of Schedule D to Form ADV. 

General partner clawback Any obligation of the general partner, its related persons, or their 

respective owners or interest holders to restore or otherwise return 

performance-based compensation to the fund pursuant to the fund’s 

governing agreements. 

General partner stakes 

investing

An investment strategy that acquires non-controlling interests in 

alternative investment managers and other entities that provide 

advisory services to, or receive compensation from, private funds. 

G10 The Group of Ten. As of the effective date of this Form PF, the G10

is comprised of: Belgium, Canada, France, Germany, Italy, Japan, the

Netherlands, Sweden, Switzerland, the United Kingdom and the 

United States.

Gold For questions regarding gold derivatives, provide the value of all

exposure to gold that you do not hold physically, whether held

synthetically or through derivatives (whether cash or physically

settled).

Government entity Has the meaning provided in Form ADV. 

Gross asset value Value of gross assets, calculated in accordance with Part 1A,

Instruction 6.e(3) of Form ADV. 

Gross notional value The gross nominal or notional value of all transactions that have been

entered into but not yet settled as of the data reporting date. For

contracts with variable nominal or notional principal amounts, the 

basis for reporting is the nominal or notional principal amounts as of

the data reporting date. 

GSE bonds Notes, bonds and debentures issued by private entities sponsored by 

the U.S. Federal Government but not guaranteed as to principal and

interest by the U.S. Federal Government.

Include bond derivatives, but do not include any positions held via

CDS (these should be recorded in the CDS category).

Guarantee For purposes of Question 63, has the meaning provided in paragraph

(a)(16)(i) of rule 2a-7. 

Guarantor For purposes of Question 63, the provider of any guarantee.
Form PF: Glossary of Terms Page 6 

Hedge fund Any private fund (other than a securitized asset fund):

(a) with respect to which one or more investment advisers (or 

related persons of investment advisers) may be paid a 

performance fee or allocation calculated by taking into account

unrealized gains (other than a fee or allocation the calculation of

which may take into account unrealized gains solely for the

purpose of reducing such fee or allocation to reflect net

unrealized losses);

(b) that may borrow an amount in excess of one-half of its net asset

value (including any committed capital) or may have gross

notional exposure in excess of twice its net asset value 

(including any committed capital); or

(c) that may sell securities or other assets short or enter into similar

transactions (other than for the purpose of hedging currency

exposure or managing duration).

Solely for purposes of this Form PF, any commodity pool about which

you are reporting or required to report on Form PF is categorized as a 

hedge fund. 

For purposes of this definition, do not net long and short positions. 

Include any borrowings or notional exposure of another person that

are guaranteed by the private fund or that the private fund may

otherwise be obligated to satisfy.

Hedge fund assets under 

management

With respect to any adviser, hedge fund assets under management are

the portion of such adviser’s regulatory assets under management

that are attributable to hedge funds that it advises.

 Holding period return Means the cumulative daily rate of return over the holding period 

calculated by geometrically linking the daily rates of return. Holding 

period return (%) = (((1 + R1) × (1 + R2) ... (1 + R10)) – 1) × 100 

where R1, R2 ... R10 are the daily rates of return during the holding 

period expressed as decimals.

Illiquid security Has the meaning provided in rule 2a-7.

Index CDS CDSs referencing a standardized basket of credit entities, including

CDS indices and indices referencing leveraged loans.

Investment grade A security is investment grade if it is sufficiently liquid that it can be 

sold at or near its carrying value within a reasonably short period of

time and is subject to no greater than moderate credit risk.

Interest rate derivative Any derivative whose underlying asset is the obligation to pay or the 

right to receive a given amount of money accruing interest at a given 

rate. Cross- currency interest rate swaps should be included in foreign 

exchange derivatives and excluded from interest rate derivatives. 
Form PF: Glossary of Terms Page 7

This information must be presented in terms of 10-year bondequivalents.

Investments in external

private funds

Investments in private funds that neither you nor your related persons

advise (other than cash management funds).

Investments in internal

private funds

Investments in private funds that you or any of your related persons

advise (other than cash management funds).

Investments in other subasset classes

Any investment not included in another sub-asset class. 

Investments in registered

investment companies

Investments in registered investment companies (other than cash 

management funds, such as money market funds, and ETFs).

ETFs should be categorized based on the assets that the fund holds 

and should not be included in this category.

Large hedge fund adviser Any private fund adviser that is required to file Section 2a of Form

PF. See Instruction 3 to determine whether you are required to file

this section. 

Large liquidity fund adviser Any private fund adviser that is required to file Section 3 of Form PF.

Large private equity fund 

adviser

Any private fund adviser that is required to file Section 4 of Form PF. 

See Instruction 3 to determine whether you are required to file this

section.

Large private fund adviser Any large hedge fund adviser, large liquidity fund adviser or large private equity fund adviser. 

LEI With respect to any company, the “legal entity identifier” assigned by 

or on behalf of an internationally recognized standards setting body 

and required for reporting purposes by the U.S. Department of the

Treasury’s Office of Financial Research or a financial regulator. In

the case of a financial institution, if a “legal entity identifier” has not

been assigned, then provide the RSSD ID assigned by the National

Information Center of the Board of Governors of the Federal Reserve

System, if any.

LCDS Loan credit default swaps.

Leveraged loans Loans that are made to entities whose senior unsecured long term

indebtedness is non-investment grade. This may include loans made

in connection with the financing structure of a leveraged buyout.

Do not include any positions held via LCDS (these should be 

recorded in the CDS category).

Liquidity fund Any private fund that seeks to generate income by investing in a 

portfolio of short term obligations in order to maintain a stable net

asset value per unit or minimize principal volatility for investors.
Form PF: Glossary of Terms Page 8

Liquidity fund assets

under management

With respect to any adviser, liquidity fund assets under management

are the portion of such adviser’s regulatory assets under management

that are attributable to liquidity funds it advises (including liquidity

funds that are also hedge funds).

Limited partner clawback An obligation of a fund’s investors to return all or any portion of a 

distribution made by the fund to satisfy a liability, obligation, or 

expense of the fund pursuant to the fund’s governing agreements.

Listed equity Direct beneficial ownership of equities, including preferred equities,

listed on a regulated exchange.

Do not include synthetic or derivative exposures to equities. ETFs

should be categorized based on the assets that the fund holds and 

should only be included in listed equities if the fund holds listed

equities (e.g., a commodities ETF should be categorized based on the

commodities it holds).

Listed equity derivatives All synthetic or derivative exposures to equities, including preferred

equities, listed on a regulated exchange.

Include single stock futures, equity index futures, dividend swaps,

total return swaps (contracts for difference), warrants and rights.

LV Value of long positions, measured as specified in Instruction 15. 

Master fund See master-feeder arrangement. 

Master-feeder arrangement An arrangement in which one or more funds (“feeder funds”) invest

all or substantially all of their assets in a single private fund (“master

fund”). A fund would also be a feeder fund investing in a master

fund for purposes of this definition if it issued multiple classes (or

series) of shares or interests and each class (or series) invests

substantially all of its assets in a single master fund. 

Maturity The maturity of the relevant asset, determined without reference to the 

maturity shortening provisions contained in paragraph (i) of rule 2a7 regarding interest rate readjustments.

MBS Mortgage backed securities, including residential, commercial and 

agency.

Do not include any positions held via CDS (these should be recorded

in the CDS category).

Money market fund Has the meaning provided in rule 2a-7. 

Most recent net asset value The net asset value reported as of the data reporting date at the end 

of the reporting fund’s most recent reporting period.

NAICS code With respect to any company, the six-digit North American Industry 

Classification System code that best describes the company’s primary

business activity and principal source of revenue. If the company
Form PF: Glossary of Terms Page 9

reports a business activity code to the U.S. Internal Revenue Service,

you may rely on that code for this purpose.

Natural gas For questions regarding natural gas derivatives, provide the value of

all exposure to natural gas that you do not hold physically, whether

held synthetically or through derivatives (whether cash or physically

settled).

Net assets under

management

Net assets under management are your regulatory assets under

management minus any outstanding indebtedness or other accrued but

unpaid liabilities.

Net asset value or

NAV

With respect to any reporting fund, the gross assets reported in

response to Question 8 minus any outstanding indebtedness or other

accrued but unpaid liabilities.

NFA The National Futures Association.

Non-investment grade A security is non-investment grade if it is not an investment grade 

security.

Non-U.S. financial 

institution

Any of the following: (i) a financial institution chartered outside the

United States; (ii) a financial institution that is separately incorporated 

or otherwise organized outside the United States but has a parent that 

is a financial institution chartered in the United States; or (iii) a 

branch or agency that resides in the United States but has a parent that 

is a financial institution chartered outside the United States.

Operations event Means for purposes of Section 5 that the reporting fund or adviser

experiences a significant disruption or degradation of the reporting 

fund’s critical operations, whether as a result of an event at a service 

provider to the reporting fund, the reporting fund, or the adviser. 

OTC With respect to any instrument, the trading of that instrument over the 

counter.

Other ABS ABS products that are not covered by another sub-asset class. 

Do not include any positions held via CDS (these should be recorded 

in the CDS category).

Other commodities Commodities other than crude oil, natural gas, gold and power. All

types of oil and energy products (aside from crude oil and natural

gas), including (but not limited to) ethanol, heating oil propane and

gasoline, should be included in this category.

For questions regarding other commodity derivatives, provide the 

value of all exposure to other commodities that you do not hold 

physically, whether held synthetically or through derivatives 

(whether cash or physically settled).

Other derivatives Any derivative not included in another sub-asset class.
Form PF: Glossary of Terms Page 10

Other loans All loans other than leveraged loans. Other loans includes (but is not

limited to) bilateral or syndicated loans to corporate entities.

Do not include any positions held via LCDS (these should be 

recorded in the CDS category) or certificates of deposit.

Other private fund Any private fund that is not a hedge fund, liquidity fund, private

equity fund, real estate fund, securitized asset fund or venture capital

fund. 

Other structured products Any structured products not included in another sub-asset class. 

Do not include any positions held via CDS (these should be recorded

in the CDS category).

Parallel fund See parallel fund structure.

Parallel fund structure A structure in which one or more private funds (each, a “parallel

fund”) pursues substantially the same investment objective and

strategy and invests side by side in substantially the same positions

as another private fund. 

Parallel managed account With respect to any private fund, a parallel managed account is any 

managed account or other pool of assets that you advise and that

pursues substantially the same investment objective and strategy and 

invests side by side in substantially the same positions as the identified

private fund. 

Performance-based 

Compensation Allocations, payments, or distributions of capital based on the 

reporting fund’s (or any of its investments’) capital gains, capital 

appreciation and/or other profit. 

Person Has the meaning provided in Form ADV. 

Power For questions regarding power derivatives, provide the value of all

exposure to power that you do not hold physically, whether held

synthetically or through derivatives (whether cash or physically

settled).

Principal office and 

place of business

Has the meaning provided in Form ADV. 

Private equity event report A quarterly report provided pursuant to the items listed in Section 6 of 

Form PF.

Private equity reporting 

event Any event that triggers the requirement to complete and file a private 

equity event report pursuant to the items in Section 6 of Form PF.

Private equity fund Any private fund that is not a hedge fund, liquidity fund, real estate

fund, securitized asset fund or venture capital fund and does not

provide investors with redemption rights in the ordinary course. 
Form PF: Glossary of Terms Page 11

Private equity fund assets

under management

With respect to any adviser, private equity fund assets under 

management are the portion of such adviser’s regulatory assets under

management that are attributable to private equity funds it advises.

Private fund Any issuer that would be an investment company as defined in 

section 3 of the Investment Company Act of 1940 but for section

3(c)(1) or 3(c)(7) of that Act.

If any private fund has issued two or more series (or classes) of equity

interests whose values are determined with respect to separate

portfolios of securities and other assets, then each such series (or

class) should be regarded as a separate private fund. This only

applies with respect to series (or classes) that you manage as if they

were separate funds and not a fund’s side pockets or similar

arrangements.

Private fund adviser Any investment adviser that (i) is registered or required to register

with the SEC (including any investment adviser that is also registered

or required to register with the CFTC as a CPO or CTA) and (ii)

advises one or more private funds. 

Private fund assets under 

management

With respect to any adviser, private fund assets under management

are the portion of such adviser’s regulatory assets under management

that are attributable to private funds it advises.

Qualifying hedge fund Any hedge fund that has a net asset value (individually or in

combination with any feeder funds, parallel funds and/or dependent

parallel managed accounts) of at least $500 million as of the last day

of any month in the fiscal quarter immediately preceding your most

recently completed fiscal quarter.

Quarterly update An update of this Form PF with respect to any fiscal quarter.

Real estate fund Any private fund that is not a hedge fund, that does not provide

investors with redemption rights in the ordinary course and that

invests primarily in real estate and real estate related assets.

Regulatory assets under 

management

Regulatory assets under management, calculated in accordance with

Part 1A, Instruction 5.b of Form ADV. 

Related person Has the meaning provided in Form ADV. 

Repo Any purchase of securities coupled with an agreement to sell the same

(or similar) securities at a later date at an agreed upon price.

Do not include any positions held via CDS (these should be recorded

in the CDS category).

Reporting period With respect to an annual update, the twelve month period ending on 

the data reporting date. 

With respect to a quarterly update, the three month period ending on 

the data reporting date. 
Form PF: Glossary of Terms Page 12

Reporting fund A private fund as to which you must report information on Form PF.

Typically, each private fund is a reporting fund. However, if you are

reporting aggregate information for any master-feeder arrangement

or parallel fund structure, only the master fund or the largest parallel

fund in the structure (as applicable) should be identified as a 

reporting fund. See Instructions 3 and 5. 

Reporting fund aggregate 

calculated value

Every position in the reporting fund’s portfolio, including cash and 

cash equivalents, short positions, and any fund-level borrowing, with 

the most recent price or value applied to the position for purposes of 

managing the investment portfolio. The reporting fund aggregate 

calculated value is a signed value calculated on a net basis and not on 

a gross basis. Where one or more portfolio positions are valued less 

frequently than daily, the last price used should be carried forward, 

though a current foreign exchange rate may be applied if the position 

is not valued in U.S. dollars. It is not necessary to adjust the 

reporting fund aggregate calculated value for accrued fees or 

expenses. Reporting fund aggregate calculated value does not need 

to be subjected to fair valuation procedures. The inclusion of income 

accruals is recommended but not required; however, the approach 

should be consistent over time. The reporting fund aggregate 

calculated value may be calculated using the adviser’s own internal 

methodologies and conventions of the adviser’s service providers, 

provided that these are consistent with information reported 

internally.

Reverse repo Any sale of securities coupled with an agreement to repurchase the

same (or similar) securities at a later date at an agreed upon price.

Risk limiting conditions The conditions specified in paragraphs (d) of rule 2a-7. 

Rule 2a-7 Rule 2a-7 promulgated by the SEC under the Investment Company

Act of 1940.

SEC U.S. Securities and Exchange Commission.

Secured borrowing Obligations for borrowed money in respect of which the borrower has

posted collateral or other credit support. For purposes of this

definition, reverse repos are secured borrowings. 

Securities lending

collateral

Cash pledged to the reporting fund’s beneficial owners as collateral in

respect of securities lending arrangements.

Securitized asset fund Any private fund whose primary purpose is to issue asset backed

securities and whose investors are primarily debt-holders.

Separately operated For purposes of this Form, a related person is separately operated if

you are not required to complete Section 7.A. of Schedule D to Form 

ADV with respect to that related person. 

7-day gross yield Based on the 7 days ended on the data reporting date, calculate the 

liquidity fund’s yield by determining the net change, exclusive of
Form PF: Glossary of Terms Page 13

capital changes and income other than investment income, in the

value of a hypothetical pre-existing account having a balance of one 

share at the beginning of the period and dividing the difference by

the value of the account at the beginning of the base period to obtain 

the base period return, and then multiplying the base period return by 

(365/7) with the resulting yield figure carried to the nearest hundredth

of one percent. The 7-day gross yield should not reflect a deduction

of shareholders fees and fund operating expenses.

Single name CDS CDSs referencing a single entity.

Sovereign bonds Any notes, bonds and debentures issued by a national government

(including central governments, other governments and central banks

but excluding U.S. state and local governments), whether

denominated in a local or foreign currency.

Include bond derivatives, but do not include any positions held via

CDS (these should be recorded in the CDS category).

Structured products Pre-packaged investment products, typically based on derivatives and

including structured notes.

Sub-asset class Each sub-asset class identified in Questions 26 and 30. 

SV Value of short positions, measured as specified in Instruction 15. 

Unlisted equity Direct beneficial ownership of equities, including preferred equities,

that are not listed on a regulated exchange.

Do not include synthetic or derivative exposures to equities.

U.S. financial institution Any of the following: (i) a financial institution chartered in the United

States (whether federally chartered or state-chartered); (ii) a financial

institution that is separately incorporated or otherwise organized in

the United States but has a parent that is a financial institution

chartered outside the United States; or (iii) a branch or agency that

resides outside the United States but has a parent that is a financial 

institution chartered in the United States. 

U.S. depository 

institution

Any U.S. domiciled depository institution, including any of the 

following: (i) a depository institution chartered in the United States, 

including any federally chartered or state-chartered bank, savings 

bank, cooperative bank, savings and loan association, or an 

international banking facility established by a depositary institution 

chartered in the United States; (ii) banking offices established in the 

United States by a financial institution that is not organized or 

chartered in the United States, including a branch or agency located in 

the United States and engaged in banking not incorporated separately 

from its financial institution parent, United States subsidiaries 

established to engage in international business, and international 

banking facilities; (iii) any bank chartered in any of the following 

United States affiliated areas: U.S. territories of American Samoa, 

Guam, and the U.S. Virgin Islands; the Commonwealth of the 
Form PF: Glossary of Terms Page 14

Northern Mariana Islands; the Commonwealth of Puerto Rico; the 

Republic of the Marshall Islands; the Federated States of Micronesia; 

and the Trust Territory of the Pacific Islands (Palau); or (iv) a credit 

union (including a natural person or corporate credit union).

U.S. treasury

securities

Direct obligations of the U.S. Government. Include U.S. treasury

security derivatives.

Unencumbered

cash

The fund’s cash and cash equivalents plus the value of overnight

repos used for liquidity management where the assets purchased are

U.S. treasury securities or agency securities minus the sum of the 

following (without duplication): (i) cash and cash equivalents

transferred to a collateral taker pursuant to a title transfer

arrangement; and (ii) cash and cash equivalents subject to a security

interest, lien or other encumbrance (this could include cash and cash

equivalents in an account subject to a control agreement).

Unfunded commitments Committed capital that has not yet been contributed to the private

equity fund by investors.

United States

person

Has the meaning provided in rule 203(m)-1 under the Advisers Act,

which includes any natural person that is resident in the United

States.

Unsecured borrowing Obligations for borrowed money in respect of which the borrower has

not posted collateral or other credit support.

Value See Instruction 15.

VaR For a given portfolio, the loss over a target horizon that will not be 

exceeded at some specified confidence level.

Venture capital fund Any private fund meeting the definition of venture capital fund in rule

203(l)-1 of the Advisers Act. 

WAL Weighted average portfolio maturity of a liquidity fund calculated

taking into account the maturity shortening provisions contained in

paragraph (i) of rule 2a-7, but determined without reference to the

exceptions in paragraph (i) of rule 2a-7 regarding interest rate

readjustments.

WAM Weighted average portfolio maturity of a liquidity fund calculated

taking into account the maturity shortening provisions contained in

paragraph (i) of rule 2a-7. 

Weekly liquid assets Has the meaning provided in rule 2a-7.