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From the Investment Management Group at law firm Seward & Kissel LLP.
In May 2023, the Securities and Exchange Commission (the SEC) adopted amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, requiring, among other things, large hedge fund advisers (i.e., hedge fund advisers with at least $1.5 billion in hedge fund assets under management) to file a current report as soon as practicable, but no later than 72 hours from the occurrence of one or more trigger events that occurs at a qualifying hedge fund that they advise. The 72-hour period begins upon the occurrence of the reporting event, or the time when the adviser reasonably believes that the event occurred, and Form PF requires the adviser to respond to the best of its knowledge on the date of the report.
Such trigger events include extraordinary investment losses, certain margin events, counterparty defaults, material changes in prime broker relationships, operations events, and certain events associated with redemptions. The current reporting events generally incorporate objective tests to allow advisers to determine whether a report must be filed.
In light of the CrowdStrike outage that occurred overnight Thursday, July 18th into early Friday morning, July 19th, large hedge fund advisers should consider whether the impact of the CrowdStrike outage triggers a current reporting event filing, in particular, due to...................... To view our full article Click here
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