Among their other regulatory obligations, private fund managers that are SEC-registered investment advisers may be subject to Form PF reporting obligations pursuant to Rule 204(b)‑1 under the Investment Advisers Act of 1940. Since its adoption in 2011, Form PF remained relatively unchanged. Recently, however, the SEC renewed its focus on the form, amending it three times since 2023 and bringing enforcement actions against investment advisers for Form PF violations. Following the amendments to the form, the SEC staff published updated and new responses to frequently asked questions (FAQs) in late 2024 and early 2025. The updated FAQs highlight many of the significant changes to Form PF introduced by the amendments and illustrate how certain Form PF filers may need to revamp their approach to completing the form, which managers should promptly address regardless of the SEC’s decision to extend the compliance date for the latest amendments until October 1, 2025. In a guest article, Morrison Foerster attorneys Kelley A. Howes and Aaron J. Russ analyze the FAQ changes most relevant to PE sponsors, including why those that advise – or that have a related person that advises – fund-of-funds, parallel fund structures, parallel managed accounts or master-feeder arrangements need to carefully reconsider their Form PF reporting obligations. See “Potential Areas of Scrutiny in Future SEC Examinations of PE Sponsors” (Jan. 9, 2025).