On October 26, 2011, the United States Securities and Exchange Commission (“SEC”) adopted final rules implementing provisions of the Dodd-Frank Act requiring investment advisers that are registered with the SEC that advise one or more private funds and manage at least $150 million in private fund assets to file Form PF with the SEC.  The information contained in Form PF is confidential and is designed, among other things, to assist the Financial Stability and Oversight Council in its assessment of systemic risk in the U.S. financial system.  Those affected by this new obligation are hedge funds, liquidity funds, and private equity funds.

Insurers and reinsurers that have investments in these types of private funds, or that are affiliated with private equity or hedge funds, should be aware of this new requirement.  To see Edward Wildman’s client advisory on the final rules, click here.