The SEC brought charges against multiple private fund advisers, each of which reported on Form ADV that they managed private fund assets of at least $150 million, for failure to file Form PF for multiple years, in violation of Rule 204(b)-1 under the Investment Advisers Act. The cases resulted in settled actions with the firms agreeing to penalties of $790,000, ranging from $90,000 to $150,000. We encourage clients to actively track regulatory filing deadlines for Form PF and other required reporting. Standish Compliance works with private fund clients to complete Form PF annually or quarterly, if required, by applicable deadlines. The SEC recently finalized multiple amendments to Form PF that will materially impact the content of annual filings in April 2025.