Cost and Timing of Filing the proposed Form PF

 GAO's estimated cost of filing the form PF

The General Accounting Office has determined that the cost of the first year of filing the form PF for all registered hedge funds, liquidity funds and private equity firms will cost over $30,0000,000 in man hours spent.  However, this does not include any costs associated with bringing the infrastructure to a level where information can be easily obtained.  It also does not include any cost consideration for a firm to establish the requested goverance standards or additonal compliance necessary to ensure that the hedge fund meets present and future requirements.    

Timing of filing Form PF

Currently, the SEC anticipates that the proposed rules requiring filing of Form PF would have a compliance date of December 15, 2011, at which time Large Private Fund Advisers would begin filing 15 days after the end of each quarter (i.e., Large Private Fund Advisers would need to make their initial Form PF filing by January 15, 2012).  According to the SEC, this timing should allow sufficient time for Large Private Fund Advisers to develop systems for collecting the information required on Form PF and prepare for filing. 

The SEC is proposing that the rules allow smaller private fund advisers until 90 days after the end of their first fiscal year occurring on or after the compliance date of the proposed rule to file their first Form PF (with the expectation that this would result in smaller private fund advisers with a December 31 fiscal year end filing their first Form PF by March 31, 2012) because the SEC anticipates that some of these advisers may require more time to prepare for their initial Form PF filing and so that the first group of private fund advisers filing Form PF would all be reporting based generally on information as of December 31, 2011.