Important Clarifications to Filing Form PF on the PFRD System

By: Jeffrey Cronin

Man and woman   signing a business contract after the conclusion

The Financial Industry Regulatory Authority (FINRA) and the Securities and Exchange Commission (SEC) periodically release frequently asked questions (FAQs) regarding the preparation of Form PF. In April 2016, FINRA released important changes to the XML schema. In order to be accepted and processed by FINRA, all XML uploads after April 16, 2016, must conform to the new format. In case you missed the updates regarding the FAQ, we’re covering them for you again.

Breaking Down the Ramifications

Before the changes to the schema, five FAQs were released. The first two covered the $150 filing fee and gave instructions on how to set up an automated filing confirmation email. The other three FAQs were more substantive in nature, and better explained the changes made to the XML. Most of these changes affect reporting funds that are also commodity pools. The amended form and XML now have a new check box in question 5(c) which states, “Check this box if the reporting fund is included in this Form PF in order to be in compliance with CFTC reporting requirements.” If this box is checked, then the information is automatically reported to the CFTC. This is a more relevant change because funds that file Form PF are given relief and therefore do not have to report sections b and c on their CPO-PQR filing.

The other FAQs regarding the new question 5(c) relate to specific XML tagging. Prior to the current schema revision, the SEC accepted “0” or a blank response in several places, including NFA ID, Large Trader ID, and Question 24. Under the new schema, this is no longer acceptable. If the bucket is not applicable, then the XML schema should read as NA.

This revision is one of many changes occurring in the industry; these changes can be difficult to understand due to the vague language of their instructions. The 100 regulatory analysts at SS&C are dedicated to deciphering these changes in a digestible format. We tailor our response to your firm’s needs and impeccable standards. Our analysts are backed by industry-leading technology that’s specifically made for Form PF. Furthermore, we have locations around the world, which allow us to service anyone with a reporting obligation. If you have questions about these recent regulation changes, or your compliance with any other regulations, contact us and we’ll help navigate you through them.

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