U.S. Securities and Exchange Commission

Annual Staff Report Relating to the Use of Data Collected from

Private Fund Systemic Risk Reports

This is a report of the Staff of the Division of Investment Management

of the U.S. Securities and Exchange Commission.

The Commission has expressed no view regarding 

the analysis, findings, or conclusions contained herein.

July 25, 2013
1

Executive Summary

The Dodd-Frank Act provided the Commission with new authority, and directed it to use this 

authority to require registered investment advisers to maintain records and file reports regarding 

the hedge funds, private equity funds and other private funds they advise. The Commission 

implemented this aspect of the Dodd-Frank Act in 2011 when it adopted a new form (Form PF) 

that requires certain registered investment advisers that advise private funds to report information 

to the Commission. 

While the primary aim of this provision was to create a source of data for the Financial Stability 

Oversight Council (“FSOC”) to use in assessing systemic risk, the Commission is using the 

information to support its own regulatory programs, including examinations, investigations and 

investor protection efforts relating to private fund advisers. The Dodd-Frank Act also required 

that the Commission report annually to Congress on how it has used the data to monitor the 

markets for the protection of investors and the integrity of the markets. This is the first annual 

report submitted to Congress to satisfy this obligation.

Since the adoption of Form PF, the Commission’s staff has focused its efforts on (i) 

implementing an electronic filing system for use by Form PF filers; (ii) resolving technical 

aspects of data security, collection and delivery; (iii) answering questions and providing filer 

assistance; (iv) establishing and overseeing Commission-wide protocols regarding how Form PF 

data is accessed and protected internally; and (v) providing FSOC, through the Office of 

Financial Research, access to the data collected. 

Due to the rolling compliance dates the Commission adopted for Form PF, the Commission has 

only recently received a complete set of initial filings. Commission staff has begun to assess the 

quality of the data collected — including evaluating the consistency of filer responses and 

differences in approaches or assumptions made by filers — and has used the data on occasion to 

obtain information regarding a specific or small number of private funds. In addition, a number 

of uses of the information have already been identified across various Commission Divisions and 

Offices. In particular, the Division of Economic and Risk Analysis has successfully incorporated 

Form PF data into its proprietary analytical tool; the Division of Investment Management’s Risk 

and Examinations Office is working to develop analytics using Form PF information that will 

allow it to monitor the risk-taking activities of investment advisers to private funds; and the

Office of Compliance Inspections and Examinations anticipates using the information collected 

on Form PF in conducting pre-examination due diligence and in risk identification. In addition, 

the Commission staff intends to provide certain aggregated, non-proprietary Form PF data to the 

International Organization of Securities Commission (IOSCO) regarding large hedge funds so 

IOSCO has a more complete overview of the global hedge fund market for a report that will be 

shared with the Financial Stability Board. In the coming months the staff will continue to assess 

data quality, and will develop data analytics incorporating Form PF data to further the 

Commission’s mission.
2

I. Introduction

The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”)1

Section 404 directed the U.S. Securities and Exchange Commission (“Commission”) to establish 

reporting requirements for investment advisers to private funds as necessary and appropriate in 

the public interest and for the protection of investors or for the assessment of systemic risk by the 

Financial Stability Oversight Council (“FSOC”).

2

 The Dodd-Frank Act specifies that such 

reporting must include certain information about private funds, including but not limited to the 

amount of assets under management, use of leverage, counterparty credit risk exposure, and 

trading practices for each private fund managed by the adviser.3 

On January 26, 2011, in a joint release with the Commodity Futures Trading Commission

(“CFTC”), the Commission proposed a new rule and a new reporting form designed to 

implement the Dodd-Frank Act Section 404 mandate.4 The Commission adopted, on 

October 31, 2011, new Form PF and Advisers Act rule 204(b)–1 that established filing 

requirements for private fund advisers regarding information for the assessment of systemic 

risk.

5

The Commission is required to submit an annual report to Congress regarding how the 

Commission has used the data collected regarding private funds under the Dodd-Frank Act to 

protect investors and the integrity of the markets.6 This report is being submitted to Congress in 

satisfaction of that requirement. This is a report of the Staff of the Division of Investment 

Management and the Commission has expressed no view regarding the analysis, findings, or 

conclusions contained herein.

 1 Public Law 111-203, 124 Stat. 1376 (2010). 

2 Section 404 of the Dodd-Frank Act (codified at Section 204(b) of the Investment Advisers Act of 1940, as 

amended (“Advisers Act”)). FSOC was created pursuant to the Dodd-Frank Act to monitor risks to the 

U.S. financial system. See Dodd-Frank Act sections 111 and 112. 

3 Section 404 of the Dodd-Frank Act.

4 See Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and 

Commodity Trading Advisors on Form PF, Investment Advisers Act Release No. 3145 (January 26, 2011), 

76 FR 8068 (February 11, 2011) (“Proposing Release”). Section 406 of the Dodd-Frank Act required that 

the Commission and the CFTC jointly promulgate the private fund adviser reporting form.

5 See Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and 

Commodity Trading Advisors on Form PF, Investment Advisers Act Release No. 3308 (October 31, 2011), 

76 FR 71128 (November 16, 2011) (“Adopting Release”). In 2012, the CFTC adopted rule 4.27 under the 

Commodity Exchange Act to implement systemic risk reporting requirements for registered commodity 

pool operators (“CPOs”) and commodity trading advisors (“CTAs”); the rule also permits CPOs and CTAs 

registered with the CFTC that are registered with the Commission as investment advisers to file Form PF 

with the Commission in lieu of filing certain systemic risk reports with the CFTC. See Commodity Pool 

Operators and Commodity Trading Advisors: Amendments to Compliance Obligations, 77 FR 11252 

(February 24, 2012).

6 Section 404 of the Dodd-Frank Act.
3

II. Background

A. Purpose of Form PF

The Commission adopted Form PF to obtain, on behalf of FSOC, data that FSOC will use to 

monitor systemic risk in U.S. financial markets. Form PF was designed with the help of FSOC 

members and will provide FSOC and the Commission with important information about the 

operations and strategies of private funds. The Commission expects that FSOC will use the 

information collected on Form PF, together with market data it obtains from other sources, to 

help FSOC monitor systemic risk. To date, FSOC has issued guidance and standards that it will 

use to determine which nonbank financial companies will be designated as “systemically 

important”7 and has indicated that it will use Form PF data to consider whether to establish 

additional sets of metrics and thresholds tailored to evaluate whether any private fund adviser or 

private fund is systemically important.8 In addition to the primary purpose to assist FSOC in its 

assessment of systemic risk, the Commission stated that it would use the information collected 

on Form PF in its regulatory programs, including examinations, investigations, and investor 

protection efforts.9

 

B. Form PF Data Reporting System

To implement systemic risk reporting requirements, the Commission has developed an electronic 

filing system, the Private Fund Reporting Depository (“PFRD”) through which advisers submit 

the information required by Form PF to the Commission. PFRD is operated under contract with 

the Financial Industry Regulatory Authority (“FINRA”) as an extension of the existing 

Investment Adviser Registration Depository (“IARD”) system (the online reporting platform 

advisers use to register on Form ADV with the Commission).10 The selection of FINRA and the 

use of the IARD platform for PFRD were the subject of a notice and order in conjunction with 

the Form PF rulemaking.11 Since July 2012, investment advisers have successfully 

electronically filed Forms PF, and amendments to those forms as required, with the Commission 

on the PFRD.

 7 See Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies, Financial 

Stability Oversight Counsel Release (April 3, 2012), 77 FR 21637 (April 11, 2012). 

8 Id.

9 See Adopting Release at Section II.

10 See Adopting Release at Section II.E. See also Approval of Filing Fees for Exempt Reporting Advisers and 

Private Fund Advisers, Investment Advisers Release No. 3297 (September 30, 2011), 76 FR 62100 

(October 6, 2011) (“Notice of Intent”). See also Order Approving Filing Fees for Exempt Reporting 

Advisers and Private Fund Advisers, Investment Advisers Release No. 3305 (October 24, 2011), 76 FR 

67004 (October 28, 2011) (“Order”); Proposing Release.

11 See Notice of Intent and Order. 
4

C. Form PF Data Reporting Requirements

Investment advisers registered with the Commission that have at least $150 million in private 

fund regulatory assets under management (“RAUM”) are required to periodically file Form PF 

with the Commission. Both the amount of information required to be reported and the frequency 

with which Form PF must be filed depend on the amount of the adviser’s RAUM and the types 

of private funds managed. Most advisers are required to file Form PF once a year, and report 

only basic information regarding the private funds they advise. This annual filing requirement 

includes general data such as the types of private funds that an adviser advises (e.g., private 

equity or hedge funds), and information relating to such funds’ size, leverage, types of investors, 

liquidity and performance. Advisers managing hedge funds must also report information about 

fund strategy, counterparty credit risk, and the use of trading and clearing mechanisms.

Large private fund advisers, however, must provide more detailed information. The content and 

frequency of this more detailed reporting is different depending on the type of private fund the 

large adviser manages:

• Advisers with at least $1.5 billion in hedge fund RAUM must file Form PF 

quarterly with respect to their hedge funds. Information required to be reported 

generally includes aggregate information on such funds’ exposures, geographical 

concentration, and turnover by asset class (not position-level information). For 

each Qualifying Hedge Fund (i.e., $500 million or more in net assets), additional 

information relating to each fund’s exposures, leverage, risk profile, and liquidity 

is required.

• Advisers with at least $1 billion in combined liquidity fund and registered money 

market fund RAUM must file Form PF quarterly with respect to their liquidity 

funds. Information required to be reported generally includes each such fund’s 

exposures, geographical concentration, and turnover by asset class (not positionlevel information), and direct and indirect forms of leverage and liquidity.

• Advisers with at least $2 billion in private equity fund RAUM must file Form PF 

annually with respect to their private equity funds. Information required to be 

reported generally relates to each such fund’s use of direct and indirect leverage 

(e.g., use of financing) and investments in financial institutions.

In adopting Form PF, the Commission was sensitive to the costs to advisers to file while 

appreciating the statutory mandate to collect a broad, representative set of systemic risk data 

regarding the private fund industry for FSOC.12 As a result, the Commission made a number of 

modifications from proposal to adoption of Form PF that were designed to mitigate concerns 

expressed by commenters. For example, the final rule does not require advisers that have less 

than $150 million in private fund assets under management to file Form PF. The Commission 

 12 See Adopting Release at Section II.A.
5

also increased the thresholds for advisers to be categorized as large private fund advisers (and 

consequently be required to report additional details of the private funds they manage) from $1 

billion to $1.5 billion for hedge funds and from $1 billion to $2 billion for private equity funds.

D. Total Filer Population

Table 1 below provides the aggregate number of filers and the number of private funds for which 

they are filing as well as when the Form PF filing is required. This data is as of May 15, 2013.13

Table 1: Total Filer Population:

Timing of 

Filing

Number

of Advisers

Number

of Funds

Smaller Advisers

($150 million private fund RAUM)

120 days from 

fiscal year end

1,662 9,963

Large Liquidity Fund Advisers

($1 billion combined liquidity fund 

and money market fund RAUM)

15 days from a 

quarter end

25 51 (liquidity funds)

Large Hedge Fund Advisers

($1.5 billion hedge fund RAUM)

60 days from a 

quarter end

482 4,189 (hedge funds)

Large Private Equity Fund Advisers

($2 billion private equity RAUM)

120 days from 

fiscal year end

171 1,931 (private equity funds)

Total 2,30514 18,01515

 13 All eligible filers were required to make initial Form PF filings no later than April 30, 2013.

14 The total number of advisers does not count multiple times those 33 large advisers that advise more than 

one type of private fund (liquidity fund, hedge fund or private equity fund). Therefore, the sum of the four 

categories will result in a larger total.

15 The total number of private funds includes 1,881 additional private funds that are not otherwise included in 

this column because these private funds are (a) advised by large private equity advisers and are not private 

equity funds, (b) advised by large hedge fund advisers and are not hedge funds or (c) advised by large 

liquidity fund advisers and are not liquidity funds.
6

E. Form PF Data Reporting 

Below sets forth certain initial aggregate data regarding the filings, as of May 15, 2013.

Types of Private Funds Advised by all Filers

6,683 – Hedge Funds ($4.061 trillion cumulative RAUM)

5,928 – Private Equity Funds ($1.603 trillion cumulative RAUM)

2,922 – Other Private Fund Type ($698 billion cumulative RAUM)

1,121 – Real Estate Funds ($299 billion cumulative RAUM)

 966 – Securitized Asset Funds ($338 billion cumulative RAUM)

 329 – Venture Capital Funds ($23 billion cumulative RAUM)

 66 – Liquidity Funds ($258 billion cumulative RAUM)

Private Fund Regulatory Assets Under Management Reported by all Filers

$7.280 trillion 

Parallel Managed Accounts16 Reported by all Filers

$1.78 trillion

Qualifying Hedge Fund Population17 Reported by all Filers

1,169 Qualifying Hedge Funds advised by 420 filers

Qualifying Hedge Fund Regulatory Assets Under Management Reported by all Filers 

$3.279 trillion

Liquidity Funds Following 2a-7 as Reported by Large Liquidity Fund Advisers

26 (51%) liquidity funds advised by Large Liquidity Fund Advisers reported that 

they are managed in compliance with all of the risk limiting conditions of Rule 

2a-7 of the Investment Company Act. 

Aggregate Gross Value of Controlled Portfolio Companies18 as Reported by Large Private 

Equity Advisers

$6.020 trillion 

 16 A Parallel Managed Account is any managed account advised by a filer that pursues substantially the same 

investment objective and strategy and invests side by side with a filer’s private fund.

17 A Qualifying Hedge Fund is a hedge fund with a net asset value of at least $500 million.

18 A Controlled Portfolio Company is 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 part of a club or 

consortium including the private equity fund.
7

III. Data Use

The Dodd-Frank Act provides specific confidentiality protections for proprietary information of 

investment advisers collected by the Commission for the purposes of assessing systemic risk of 

private funds. Consistent with the enhanced confidentiality provisions established under the 

Dodd-Frank Act, Commission staff has designed and implemented controls and systems for the 

handling of Form PF data across the agency. Senior officials from various Divisions and Offices 

within the Commission are members of a Steering Committee that is tasked with developing a 

consistent and agency-wide approach to accessing, and the using, sharing, and security of, Form 

PF data.

The Steering Committee also works with other federal agencies that request Form PF data to 

address the confidentiality obligations under the Dodd-Frank Act. Significantly, in accordance 

with the Dodd-Frank Act, Form PF data has been made available to FSOC through the Treasury 

Department’s Office of Financial Research (“OFR”), which was established under the DoddFrank Act19 to support FSOC in fulfilling FSOC’s purposes and duties. Prior to the delivery of 

Form PF data to OFR,20 the Steering Committee and OFR representatives agreed to principles

for the use and protection of Form PF Data and the Steering Committee worked with OFR to 

assess OFR’s information technology policies and procedures.

21

As noted above, although the information collected on Form PF is primarily intended to assist 

FSOC in its systemic risk monitoring obligations under the Dodd-Frank Act, the Commission is 

using information in its regulatory programs, including examinations, investigations, and 

investor protection efforts relating to private fund advisers.22 To that end, Commission staff is 

actively developing data analytics incorporating Form PF data to further the Commission’s 

mission. 

Due to the rolling compliance dates the Commission adopted for Form PF, the Commission has 

only recently received a complete set of initial filings. It is anticipated that the utility of the 

private fund data collected on Form PF will develop as the staff’s experience with the 

information evolves. A number of uses of the information have already been identified across 

various Commission Divisions and Offices.

The Division of Economic and Risk Analysis (“DERA”) has successfully incorporated Form PF 

data into its proprietary analytical tool. DERA also is actively working with various experts 

across the Commission to develop and deliver more complex analytics (e.g., aberrational 

performance, systemic trend and peer analysis) using Form PF data and other data sources. For 

 19 See section 152 of the Dodd-Frank Act.

20 See section 153 of the Dodd-Frank Act.

21 Pursuant to the Dodd-Frank Act, other federal departments or agencies, or self-regulatory organizations 

may request Form PF data for purposes within the scope of their jurisdiction. Each recipient of Form PF 

data is required to maintain the confidentiality of that information consistent with the heightened level of 

confidentiality established by the Dodd-Frank Act. See section 404 of the Dodd-Frank Act (codified at 

section 204(b) of the Advisers Act). At this time, Form PF data has not been provided to other agencies.

22 See Adopting Release at Section V.A.
8

example, the Commission’s Asset Management Unit of the Division of Enforcement is working 

collaboratively with DERA to develop analytic tools to integrate Form PF data into research and 

due diligence related to investigative work and other enforcement matters.

The Division of Investment Management’s Risk and Examinations Office (“REO”) is also 

working with DERA to develop analytics that will allow REO to monitor the risk-taking 

activities of investment advisers to hedge funds and other private funds as part of REO’s risk 

monitoring program, as well as to provide internal periodic reports regarding the private fund 

industry generally and with respect to particular market segments. The Division of Investment 

Management also will use Form PF data to inform policy and rulemaking with regard to private 

funds, and intends to use aggregated, non-proprietary data in its consultative work with other 

securities regulators on issues of mutual interest. For example, certain aggregated, nonproprietary Form PF data (as detailed in Appendix A) is expected to be shared with IOSCO, in 

conjunction with its survey of the global hedge fund industry. 

The Commission’s Office of Compliance Inspections and Examinations (“OCIE”) anticipates 

using the information collected on Form PF in several ways. For examination teams conducting 

pre-examination research and due diligence, Form PF data will provide greater insight into the 

activities of the fund(s) managed by an adviser and result in better exam scoping and risk 

identification. OCIE has also begun work with DERA to develop periodic reports that analyze 

data across a wide spectrum of filers to help identify trends and possible emerging risks in the 

private fund industry. This effort could enhance the development of examination priorities, 

resource allocation and training-related initiatives. OCIE also is working to develop a series of 

analytics and metrics that will allow staff to identify possible red flags at firms, which could 

trigger examinations. Similarly, thematic examinations also could be initiated as a result of this 

analysis.

As noted above, the Commission’s experience with Form PF data is in its early stages and the 

utility of the data collection will develop as the collective experience with the information 

evolves. Of critical importance to expanding the utility of the data is confidence in the 

information provided by filers. Commission staff also is proactively trying to improve data 

quality by, for example, issuing FAQs on interpretive issues that commonly arise from filers. In 

addition, Commission staff has performed an initial analysis of Form PF Data and identified 

certain data anomalies attributable to filer error. Commission staff has begun, and will continue 

to contact filers to inform them of the anomalous data and request that advisers submit curative 

amendments to their Form PF filings. Data quality also is expected to improve as filers become 

more familiar with the Form’s requirements and the methods of calculation.
9

IV. Conclusion

Each investment adviser registered with the Commission that has at least $150 million in private 

fund RAUM recently completed an initial Form PF filing. The information collected on Form 

PF is intended to primarily support FSOC and the assessment of systemic risk. Since adoption of 

the new reporting requirement, the Commission staff has implemented the new electronic form 

filing requirement, established internal protocols regarding access to the data collected and 

provided FSOC, through OFR, access to the PF Data. The information collected on Form PF 

will also support the Commission’s regulatory programs relating to private fund advisers. 

Commission staff has begun to assess the quality of the data collected and in the coming months 

the staff will develop and refine data analytics incorporating Form PF data to further the 

Commission’s mission.
1

Appendix A

IOSCO has requested that the Commission share certain aggregated, non-proprietary Form PF 

data in order for IOSCO to draft a report to the Financial Stability Board. The Task Force on 

Unregulated Financial Entities was launched by IOSCO in response to the financial crisis and 

directed to develop recommended regulatory approaches to mitigate risks associated with the 

trading and traditional lack of transparency of hedge funds. One such recommendation was to

encourage regulators to share data related to systemic risk.1 Commission staff intends to provide 

IOSCO with the following aggregated, non-proprietary Form PF data regarding Qualifying 

Hedge Funds so IOSCO has a more complete overview of the global hedge fund market for a 

report that will be shared with the Financial Stability Board. In addition, Commission staff 

intends to provide IOSCO with information explaining in detail what Form PF requires advisers 

to report and qualifications regarding this data set in light of international comparability issues. 

Pursuant to IOSCO’s request, all of the below information is from Form PF data filed between 

October 1, 2012 and December 31, 2012. During this time, only advisers with at least $5 billion 

in assets under management attributable to hedge funds were required to file Form PF.

Number of Qualifying Hedge Funds2 reported on Form PF

823 Qualifying Hedge Funds

Domicile of Qualifying Hedge Funds reported on Form PF3

Domicile Percent

CAYMAN ISLANDS 45%

UNITED STATES 41%

BRITISH VIRGIN ISLANDS 3%

LUXEMBOURG 3%

BERMUDA 2%

IRELAND 2%

OTHER 4%

Domicile of Qualifying Hedge Funds reported on Form PF by net asset value4

Domicile Percent

CAYMAN ISLANDS 51%

UNITED STATES 35%

BRITISH VIRGIN ISLANDS 7%

 1 See IOSCO Final Report on Hedge Funds Oversight, Recommendation 6 available at

http://www.iosco.org/library/pubdocs/pdf/IOSCOPD293.pdf.

2 A Qualifying Hedge Fund is a hedge fund with a net asset value of at least $500 million.

3

 This data was calculated using Form PF and Form ADV data.

4

 This data was calculated using Form PF and Form ADV data.
2

LUXEMBOURG 2%

IRELAND 1%

BERMUDA 1%

OTHER 3%

Aggregated Net Asset Value of All Qualifying Hedge Funds reported on Form PF

$1.47 trillion

Aggregated Regulatory Assets Under Management of Investment Advisers Reporting Qualified 

Hedge Funds on Form PF5

$10.05 trillion

Qualifying Hedge Fund Number Breakdown by Investment Adviser Location6

Investment Adviser Country Location Number of Qualifying Hedge Funds

UNITED STATES 735

UNITED KINGDOM 59

BRAZIL 14

GUERNSEY 6

AUSTRALIA 4

BERMUDA 2

BAHRAIN 1

JERSEY 1

SINGAPORE 1

Aggregated Dollar Amount of Parallel Managed Accounts7 related to Qualifying Hedge Funds 

reported on Form PF

$275 billion

 5

 This data was calculated using Form PF and Form ADV data.

6

 This data was calculated using Form PF and Form ADV data.

7

 A Parallel Managed Account is any managed account advised by a filer that pursues substantially the same 

investment objective and strategy and invests side by side with a filer’s private fund.
3

Aggregated Dollar Amount of Borrowings8 of Qualifying Hedge Funds reported on Form PF

$1.06 trillion

Number of Qualifying Hedge Funds reported on Form PF having a single primary strategy or 

multi-strategy

- 569 single primary strategy

- 252 multi-strategy

- 2 did not report

Percent of Aggregated Qualifying Hedge Funds reported on Form PF portfolios capable of 

being liquidated within:

Percent of Net Asset Value Time Period

27% 1 day or less

53% 7 days or less

71% 30 days or less

80% 90 days or less

85% 180 days or less

89% 365 days or less

100% 365 days or more

Aggregated Number of Qualifying Hedge Funds reported on Form PF that provide investors 

with withdrawal or redemption rights in the ordinary course.

- 603 provide withdrawal/redemption in the ordinary course

- 220 do not provide withdrawal/redemption in the ordinary course

Percent of Aggregated Qualifying Hedge Funds reported on Form PF Net Asset Value that may 

be withdrawn or redeemed

- 15% of Qualifying Hedge Funds’ aggregated net asset value is not available 

for withdrawal/redemption in the ordinary course

- 77% of Qualifying Hedge Funds’ aggregated net asset value may be subjected 

to a suspension of investor withdrawal/redemptions by an adviser or fund 

governing body

- 52% of Qualifying Hedge Funds’ aggregated net asset value may be subjected 

to material restrictions on investor withdrawals/ redemptions (e.g., “gates”) by 

an adviser or fund governing body

 8 Borrowings include the secured and unsecured borrowings of a fund, but do not include other significant 

methods of incurring leverage, such as the inherent leverage associated with a fund’s use of derivatives. 

See Form PF Frequently Asked Questions, available at 

http://www.sec.gov/divisions/investment/pfrd/pfrdfaq.shtml.
4

- 1% of Qualifying Hedge Funds’ aggregated net asset value is subject to a 

suspension of investor withdrawals/redemptions

- 3% of Qualifying Hedge Funds’ aggregated net asset value is subject to a 

material restriction on investor withdrawals/redemptions (e.g., a “gate”)

Percent of Aggregated Qualifying Hedge Funds reported on Form PF net asset value investors 

are capable of liquidating within:

Percent of Net Asset Value Time Period

7% 1 day or less

9% 7 days or less

24% 30 days or less

43% 90 days or less

59% 180 days or less

74% 365 days or less

100% 365 days or more