/regulatory-reporting

name: regulatory-reporting
description: "Guide regulatory filing mechanics and deadlines for investment advisers, broker-dealers, and large traders — which forms to file, where, and by when. Use when the user asks about Form PF filing thresholds, 13F institutional holdings reports, 13H large trader filings, Form ADV amendment filing timing (including the annual updating amendment filed via IARD), FOCUS report preparation, blue sheet requests, CAT reporting infrastructure, or FINRA short interest and TRACE reporting. Also trigger when users mention 'filing deadline calendar', 'do we need to file Form PF', 'crossed the $100M 13F threshold', 'CAT clock synchronization', 'how to respond to a blue sheet request', or 'FOCUS report errors'. (For what the ADV brochure must contain and when it must be delivered to clients, use client-disclosures.)"

Regulatory Reporting

Regulatory status current as of June 2026 — verify effective dates, dollar thresholds, and pending rulemakings against current SEC/FINRA/FinCEN sources before advising.

Core Concepts

Form ADV Amendments

Registered investment advisers must keep Form ADV current through two amendment mechanisms:

**Annual updating amendment** — Must be filed within 90 days of the adviser's fiscal year end (Rule 204-1 under the Investment Advisers Act of 1940). The annual amendment requires the adviser to review and update all items on Form ADV Parts 1, 2A, and 2B. The adviser must also deliver or offer to deliver the updated brochure (Part 2A) to existing clients within 120 days of fiscal year end, along with a summary of material changes.

**Other-than-annual amendments (interim/prompt amendments)** — Certain items on Form ADV must be amended promptly when information becomes inaccurate. "Promptly" is generally interpreted as within 30 days of the event, though some changes require faster action. Items requiring prompt amendment include:

• Changes in the adviser's organizational structure, control persons, or ownership (Part 1, Items 1, 2, 3, 7, 10, 11)
• Changes in disciplinary history (Part 1, Item 11, DRPs)
• Changes in the adviser's financial condition that would require disclosure under Part 2A Item 18
• Changes to the brochure (Part 2A) that are material and that clients or prospective clients should know about — including changes to types of advisory services, fee schedules, methods of analysis, risk factors, material conflicts, disciplinary events, or financial condition

**Items that may wait for the annual amendment** — Statistical information (AUM, number of clients), non-material updates to biographical information, and administrative details that do not affect client decision-making.

**Filing via IARD** — All Form ADV amendments are filed electronically through the Investment Adviser Registration Depository (IARD) system. Filing fees apply. State notice filings are typically triggered automatically upon SEC filing for advisers relying on SEC registration.

**State notice filings** — SEC-registered advisers operating in multiple states must make notice filings with each state in which they have a place of business or meet the de minimis threshold. IARD facilitates most state notice filings alongside the SEC filing.

**Form ADV-W (Withdrawal)** — An adviser withdrawing from SEC registration files Form ADV-W via IARD. Partial withdrawal (from specific states) or full withdrawal from SEC registration. A withdrawal filing becomes effective 60 days after filing unless the SEC institutes proceedings. Firms must maintain books and records for the applicable retention periods after withdrawal.

Form PF (Private Fund Reporting)

SEC Form PF, required under Section 204(b) of the Advisers Act and Rule 204(b)-1, applies to SEC-registered investment advisers that manage one or more private funds. (The dollar thresholds below are set by rule and are not inflation-indexed; unchanged as of 2026.)

**Filing thresholds and frequency:**

• **Large private fund advisers to hedge funds** — advisers with at least $1.5 billion in hedge fund AUM must file quarterly within 60 days of quarter end. They report on each qualifying hedge fund individually.
• **Large private fund advisers to liquidity funds** — advisers with at least $1 billion in combined money market fund and liquidity fund AUM must file quarterly within 15 days of quarter end.
• **Large private fund advisers to private equity funds** — advisers with at least $2 billion in private equity fund AUM must file annually but report more detailed information on each qualifying PE fund.
• **Smaller private fund advisers** — all other SEC-registered advisers with at least $150 million in private fund AUM file annually within 120 days of fiscal year end. They report aggregate information across all advised private funds.

**Content of Form PF filings:** AUM and NAV for each reported fund; borrowings and leverage (gross and net); investor concentration (largest investors as a percentage of NAV); asset class exposure and geographic breakdown; counterparty credit exposure (top counterparties); trading and clearing practices (exchange-traded vs OTC); liquidity of portfolio positions; side pocket and gate usage; performance data; investment strategy classification; use of high-frequency trading strategies.

**2023 Amendments — Current Reporting (effective 2024):** The SEC adopted amendments to Form PF requiring current reporting of certain triggering events:

• **Large hedge fund advisers** must report within 72 hours of: extraordinary investment losses (20% or more of a reporting fund's NAV over a rolling 10-business-day period), significant margin and default events (failure to meet a margin call that exceeds the reporting fund's NAV by 5% or more), counterparty defaults, material changes in prime broker relationships, changes in unencumbered cash falling below a reporting fund's requirement, and operations events (significant disruption to key operations).
• **All Form PF filers for priva