Form Pf - Reporting Form For Investment Advisers To Private Funds And Certain Commodity Pool Operators And Commodity Trading Advisors Page 9
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64Form PF: General Instructions
Page 9
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 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
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