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March 2013

Publications for theAlternativeInvestmentsIndustry

For more information, please contact your local PwC

representatives or the contact listed on the back of

this card. To download these publications, visit us at

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Our view, validated by conversations with UShedge fund investors, managers and otherindustry participants

From black box to open bookUS hedge fund trust and transparency

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From black box to openbook: US hedge fund trustand transparency

Introduction

The August 29, 2012 filing deadline for first-time Form PF (the Form ) filers has come and gone. Before the dust has even begun to settle, advisers are already compiling data and responses for the next filing deadline on November 29, 2012. With little time between filings, many of these early filers are leveraging their experiences from their first filing and in some cases evaluating various third-party and/or technology solutions to make the process less painful and time consuming. Those that have yet to file know that they have a demanding task ahead of them, but can learn what to expect and how to better manage this tedious process from their industry peers. Through its work with several first-time filers, PwC has identified key trends and issues that are valuable to all filers as the reporting requirement continues to phase in for registered private fund investment advisers.

Manual processing vexes advisers

To better understand Form PF implementation issues, PwC recently conducted a survey of private fund adviser clients. Their biggest concern (58% responded as such) was the manual nature of the process used to gather and report the information for Form PF. More than 60% of advisers responding to the survey stated that they are manually compiling data and are relying less on technology or third party solutions.

While advisers can expect the industry to develop more automated solutions over time, whether it s through the adviser s technology team or through an administrator or technology vendor, most first-time filers were in an unfortunate position they had to work

through the tedious process of gathering granular pieces of data, tagging or enhancing that data in its systems or reports so that it is usable, calculating responses to questions on a spreadsheet, and then manually inputting those responses into the Form. As a result, the filing process was vulnerable to human error, and the staff of the various departments that were engaged to complete the Form were sometimes overwhelmed with the significant time burden of enriching and compiling the necessary data.

Whether an adviser plans to implement a more automated solution over time or continues to conduct the filing exercise manually, in our view, the adviser should develop a sound and controlled process that is repeatable and documented in some form of a regulatory filing procedure that can serve as a governance framework for regulatory filings. This framework should be described in a narrative form and illustrate the firm s regulatory filing accountability, responsibility, and ownership structure.

Integral to establishing this governance framework is designating an individual within the firm as the head of regulatory reporting. This individual should have a strong grasp of the technical accounting and operational functions unique to the adviser and should have sufficient authority to drive the Form PF process. The responsibilities of the head of regulatory reporting can also extend beyond Form PF and address other filings like Form CPO-PQR, Large Trader, upcoming AIMFD requirements, etc. Under the head of regulatory reporting should be designated individuals within each operational group (i.e., legal, operations, accounting, investor relations, risk, etc.) who are responsible for the data gathering exercise for his/her specific group.

FS Regulatory Brief Advisers key concerns on Form PF implementation November 2012

FS Regulatory BriefAdvisers’ key concerns onForm PF implementation

Asset ManagementM&A InsightsThe way forward

This publication providesperspectives on the recenttrends and outlook relatingto asset managementmergers and acquisitionsactivity in the US and major global markets.

February 2012

www.pwc.com/us/assetmanagement

Asset Management M&AInsights: The way forward

Top issues facing asset managers

April 2012

www.pwc.com/us/assetmanagement

Top issues facingasset managers

Part of an ongoing series

Reporting by Private Fund Advisers on Form PF SEC and CFTC Adopt Final Rules Requiring Registered Advisers to Private Funds to File New Form PF

November 2011

In October 2011, the Securities and Exchange Commission (SEC) and the Commodities Futures Trading Commission (CFTC) adopted final rules as mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank, or the Act) to require registered advisers to report on new Form PF information concerning the private funds they advise. Focused on private funds’ basic operations and strategies, the information reported on Form PF will aid the SEC, the CFTC, and the Financial Stability Oversight Council (FSOC) in their assessment of systemic risk. While the final rules on Form PF were anticipated, they are complex, and will have significant operational impact on registered advisers to private funds. This A Closer Look describes the final rules requiring new Form PF and their impact.

A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act

To view our other A Closer Look pieces on Dodd-Frank, please visit www.pwcregulatory.com

Reporting by Private FundAdvisers on Form PF:SEC and CFTC Adopt FinalRules Requiring RegisteredAdvisers to Private Funds toFile New Form PF

Financial Services Advisory Practice

Form PF – How we can help asset managers Fall 2012

www.pwcregulatory.com

Financial Services AdvisoryPractice: Form PF – How wecan help asset managers

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12th Annual AlternativeInvestments SeminarHighlights

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For more information onthese publications, pleasecontact Annie Fileta atanne.n.fileta@us.pwc.com

November 2012

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