While 2012 may go down in the books as the year of Form PF, it does not mark the end of Form PF — in fact, it’s only the beginning. In the next phase of the rule, advisers that manage at least $150 million RAUM in private funds will need to file either 60 or 120 days after year-end, depending on fund size. Going forward, updates will be required quarterly, meaning firms need to ensure they have procedures in place for not just their first, but subsequent filings as well. The good news is the industry can learn from the experience and mistakes of the first filers as the process continues to move forward.
Advise Technologies, who helped more than half of the first round of Form PF filers do so successfully, is going to be issuing a white paper next week titled, “Top 10 Tips from First Round Filers,” to help guide those still new to the process.
Following are the essential tips Advise suggests:
· Start early and plan ahead as the filing will take longer than anticipated
· Complete a mock filing to ensure all the pieces are in place
· Get in the depths of the data
· Learn the Form PF lingo
· Ensure consistency across filings
· Look at the form as the sum of its parts
· Create an internal playbook
· Be flexible
· Automate the process
· Determine how and if to share the data with investors