Form Pf - Reporting Form For Investment Advisers To Private Funds And Certain Commodity Pool Operators And Commodity Trading Advisors Page 4
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64Form 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
For purposes of reporting information in
private fund is a qualifying hedge fund
Sections 1b, 1c, 2b, 3 and 4
You must aggregate any private funds that
You may, but are not required to, report
are part of the same master-feeder
answers on an aggregated basis for any
arrangement (even if you did not, or were
private funds that are part of the same
not permitted to, aggregate these private
master-feeder arrangement (even if you
funds for purposes of Form ADV Section
did not, or were not permitted to, aggregate
7.B.1)
these private funds for purposes of Form
ADV Section 7.B.1)
You must aggregate any private funds that
You may, but are not required to, report
are part of the same parallel fund structure
answers on an aggregated basis for any
private funds that are part of the same
parallel fund structure
Any dependent parallel managed account
You are not required to report information
must be aggregated with the largest private
regarding parallel managed accounts
fund to which that dependent parallel
(except in Question 11)
managed account relates
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