Form PF, required under Rule 204(b)-1 of the Investment Advisers Act, is the non-public reporting form that SEC-registered investment advisers to private funds file with the SEC and share with the FSOC. It collects AUM, leverage, counterparty exposure, liquidity, performance, and investor composition across hedge funds, liquidity funds, private equity funds, and other private fund types. Section-specific reporting is triggered by AUM thresholds — large hedge fund advisers, large liquidity fund advisers, and large private equity fund advisers file deeper sections — and the SEC's recent amendments added current reporting and event-driven quarterly filings for certain advisers. Many '40 Act fund sponsors also file Form PF because they operate affiliated hedge funds, private credit vehicles, or PE strategies alongside their registered funds.
The Form PF Data Problem
Advisers that run parallel fund regimes have parallel data stacks. The '40 Act fund operation is oriented around the fund administrator, transfer agent, custodian, and N-PORT filer. The private fund operation is oriented around prime brokers, the private fund administrator, and the investor services portal. Form PF asks questions that cut across both worlds — exposure by asset class, counterparty concentration, leverage — but the data lives in separate systems that were never meant to be queried together.
Prime broker data for hedge fund strategies sits in daily files from Goldman Sachs, Morgan Stanley, J.P. Morgan, BofA, BNY Mellon Pershing, and others. Custodian and fund admin data for '40 Act funds sits in files from Ultimus, SEI, ALPS, SS&C, BNY Mellon, State Street. Counterparty aggregation at the adviser level — the way Form PF wants it reported — requires mapping every trading counterparty, swap dealer, and repo book across entities to a single normalized entity. Nobody maintains that master by default.
Investor composition for '40 Act funds lives on the TA side (DST, Ultimus, SS&C GIDS), organized around registered shareholders. Investor composition for private funds lives in subscription documents, side letters, and the investor services system, organized around LPs and capital commitments. Form PF asks for a unified view — types of investors, concentration, qualified purchaser status, fund-of-funds ownership — that neither system alone can provide.
Event-triggered reporting, added by the Form PF amendments, compressed the calendar. Large hedge fund advisers now report certain events (significant margin events, counterparty defaults, large drawdowns) within tight current-reporting windows. Private equity advisers file event-driven quarterly updates for adviser-led secondaries and similar events. The timing only works if the underlying data — trades, positions, financing, investor identity — is already assembled and queryable when the clock starts.
What Unified Form PF Data Requires
Cross-Entity AUM Calculation
Regulatory AUM rolled up at the adviser level across '40 Act funds, private funds, separately managed accounts, and sub-advisory relationships — with the fund-level detail preserved for drill-down.
Counterparty Exposure Aggregation
A single counterparty master that maps every prime broker, swap dealer, repo counterparty, and OTC derivative counterparty across funds so exposure concentrations appear at the adviser level.
Leverage & Financing Data
Gross and net leverage, borrowings by source, financing terms, collateral posted — normalized across prime broker files and fund admin NAV records so the numbers on Form PF tie to the underlying positions.
Investor Composition Layer
A unified investor model that joins '40 Act shareholder data from the TA with private fund LP data from the investor services platform, resolving qualified purchaser and beneficial ownership status across the book.
Event-Trigger Detection
Automated monitoring for the conditions that trigger current reporting — margin events, counterparty defaults, drawdown thresholds, secondary transactions — so the timing clock starts with evidence already assembled.
Audit-Ready Lineage
Every number on Form PF traced back to its source system, ingestion timestamp, and transformation history so examiners, auditors, and the adviser's own compliance team can reconstruct each filing.
How Milemarker Supports Form PF
Milemarker ingests the data both sides of the business already produce and normalizes it into a firm-owned Snowflake warehouse. On the private fund side, prime broker files from Goldman Sachs, Morgan Stanley, J.P. Morgan, BofA, and BNY Mellon Pershing flow in alongside the private fund administrator's NAV, positions, and investor records. On the '40 Act side, fund admin data from Ultimus, SEI, ALPS, SS&C, BNY Mellon, or State Street joins transfer agent data from DST, Ultimus, or SS&C GIDS and custodian holdings feeds. Both books land in one schema.
A unified counterparty master resolves prime brokers, swap dealers, repo counterparties, and OTC derivative counterparties into a single entity across funds. Exposure rolls up at the adviser level the way Form PF asks for it, while the fund-level detail remains addressable behind each aggregate. The investor composition layer joins registered shareholder records from the TA side with LP subscription data from the private fund side, so qualified purchaser and beneficial ownership questions can be answered against one model.
Milemarker Relay workflows monitor the warehouse for event-reporting triggers. When a margin event, counterparty default, large drawdown, or adviser-led secondary crosses a Form PF threshold, Relay surfaces the condition to compliance with the supporting positions, counterparty exposure, and investor records already pulled. The timing windows for current and quarterly event reporting work because the evidence is assembled continuously, not pulled ad hoc.
Navigator AI lets the compliance and finance team ask questions in plain English across the combined book: "what is our counterparty exposure to Goldman across all funds," "which private funds crossed 1.5x leverage last quarter," "how did our credit exposure to a specific swap dealer change after the last margin call." Answers come from the firm's own Snowflake warehouse with source lineage, which matters when the filer needs to justify a number to a regulator.
Milemarker does not replace the Form PF filing platform. Confluence, Arcesium, SS&C, and similar tools continue to generate the XML and submit it. What changes is that the inputs come from one reconciled warehouse instead of a stack of spreadsheets assembled fund by fund each quarter. The firm owns the Snowflake instance; the lineage and historical record belong to the adviser.
Who This Is For
Dual Registrants
Advisers registered with the SEC that run both '40 Act funds and private funds carry the full weight of both regimes. N-PORT, N-CEN, and Rule 38a-1 on one side; Form PF, Form ADV Part 1A Section 7.B.1, and the private fund adviser rules on the other. A unified data layer turns the two parallel compliance calendars into shared infrastructure.
Large Hedge Fund Advisers
Large hedge fund advisers — those crossing the $1.5 billion threshold for quarterly Section 2 reporting — face the deepest Form PF burden and the tightest current-reporting clock. Counterparty exposure, financing, unencumbered cash, and stress scenarios need to be queryable at the adviser level, not reconstructed fund by fund. The same infrastructure that serves the '40 Act operations can serve the hedge fund book.
Large Liquidity Fund Advisers
Advisers to liquidity funds — money-market-style vehicles not registered under the '40 Act — file detailed Section 3 reports. The data model is close enough to a '40 Act money market fund that a single platform can support both. Portfolio composition, weighted average maturity, investor concentration, and daily liquidity metrics live in the same warehouse whether the fund is registered or private.
PE Sponsors with '40 Act Funds
Private equity sponsors that have added interval funds, tender-offer funds, or BDCs alongside their PE strategies end up running both sides. Firms like Flat Iron Wealth have followed that path, bringing '40 Act vehicles alongside existing PE funds. Form PF's PE-specific sections (Section 4 and the event-driven reporting for adviser-led secondaries) and the '40 Act regime share the same underlying investor, counterparty, and position data.
Operations and Compliance Leaders
Chief Operating Officers, Chief Compliance Officers, and heads of fund operations own the reporting calendar for both regimes. A unified data layer gives the ops function a single queryable foundation for every filing — Form PF, Form ADV, N-PORT, N-CEN, annual 38a-1 — instead of parallel assembly lines. The team stops being stitchers of data and becomes investigators of what the data shows.