Form Pf - Reporting Form For Investment Advisers To Private Funds And Certain Commodity Pool Operators And Commodity Trading Advisors Page 5
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64Form PF: General Instructions
Page 5
You must treat any private fund or parallel
You should not report information for any
managed account advised by any of your
private fund advised by any of your related
related persons as though it were advised
persons unless you have identified that
by you (including related persons that you
related person in Question 1(b) as a related
have not identified in Question 1(b) as
person for which you are filing Form PF
related persons for which you are filing
Form PF, though you may exclude related
persons that are separately operated)
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 master-feeder 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
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