Apr 26, 2013. The SEC released 3 additional FAQs for Form PF:
FAQ A.6 – If you advise a private fund but do not provide “continuous and regular supervisory or management services” in accordance with Instruction 5.b.(3) of Form ADV Part 1A, the SEC Staff would not recommend enforcement action if you do not report for such Fund on Form PF. However, the fund must be reported on Form ADV, section 7.B.1 if not reported by another adviser.
FAQ 14.1 – When filing an annual or fourth quarter update, you are not required to categorize each asset and liability in accordance with the leveling hierarchy, only those assets and liabilities that are required to be presented in the reporting fund’s financial statements at fair value.
FAQ 76.1 / 77.2 – The list of NAICS codes available as valid responses on Form PF is a subset of the complete list of codes. When the PFRD system rejects or does not list the specific NAICS code most applicable to a particular portfolio company, you should use the “parent” or more general level NAICS code.
The complete list of FAQs is available on the SEC’s website here: http://www.sec.gov/divisions/investment/pfrd/pfrdfaq.shtml
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