News & Events

Corporate Partner David Blass was quoted extensively in a Law360 article titled “SEC's Onerous Form PF Proposal Puts PE Firms On Notice.” The article offers an overview of newly-proposed rules from the SEC related to Form PF, including those that would require PE funds to make the filing within one business day of certain triggering events. David explained that, “It feels like it sets up firms for potential compliance pitfalls more than it provides a reasonable method to inform the [SEC] and its staff of important events,” posing as an example the challenge firms could face, given the severely shortened reporting timelines, if a key employee happens to be out on the day a filing is required. He suggested that the agency’s goals might instead be better achieved through other means, such as requiring fund managers to disclose reportable information in a “prompt” Form ADV filing or amendment. “That would be a more logical place to require that disclosure rather than the Form PF, and that kind of timing makes more sense, too,” he said.

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