Annual filing for all advisers
All private fund advisers with at least $150M in private fund assets must file annually. We verify fund classification, aggregation, and data tie to audited financials.
The most rigorous Form PF filing service a private fund adviser can use.
FundLedger PF assembles a documentation-complete Form PF filing — every required section, every data reconciliation, the aggregation logic, the audit trail, and the examiner-ready binder — checked against the letter of SEC Form PF instructions and the Advisers Act before a compliance specialist releases it.
Every section of Form PF (1, 3, 4, 5)Data reconciled to audited financialsAggregation across master-feeder structuresSpecialist release on every filing5-business-day SLA (annual); 72-hour SLA (event)
Why filings fail
A single missing data point or mis-mapped field can trigger an SEC inquiry.
A private fund adviser's Form PF filing is only as strong as the data behind it. Miss a required aggregation, mis-map a fund to the wrong question set, fail to reconcile a figure to the audited financials, or miss a 72-hour event-report deadline — and the filing can be flagged, examined, or result in penalties.
Most advisers run this by hand, from memory, once or twice a year. The instructions have not been read end-to-end since the last filing. That is exactly where completeness gaps hide.
FundLedger PF exists to close that gap with a single, exhaustive standard applied identically to every filing.
$790K
in penalties imposed on seven advisers in one 2024 SEC sweep for Form PF failures
The benchmark
Measured against the letter of the Form PF instructions — section by section.
We do not summarize the rules and hope. Every filing is scored against a versioned rule pack tied to the exact text of Form PF and the Advisers Act. These are the provisions each filing is held to.
Quarterly filing for large advisers
Large hedge fund advisers ($1.5B+ AUM) and large PE advisers ($2B+ AUM) must file quarterly within 60 days of quarter-end. We reconcile exposure, liquidity, and counterparty data.
72-hour event reporting
Large hedge fund advisers must file current reports within 72 hours of triggering events (extraordinary loss, margin spike, counterparty default, large redemption). We monitor triggers and draft the report.
Data reconciliation to books
Every numeric field must foot to the audited financial statements or be explicitly reconciled. We cross-check against fund administrator, prime broker, and GL data.
Aggregation across fund structures
Master-feeder and parallel fund structures must be aggregated correctly. We map each fund to the correct question set and aggregate per SEC guidance.
Penalty-backed compliance
The SEC imposed $790K in penalties on seven advisers in 2024 for repeated filing failures. We ensure every filing is complete, accurate, and on time.
How a filing is built
Intake to specialist release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human compliance specialist signs every release. That order is never reversed.
01
Data Gap Scan
Upload fund financials, administrator reports, and prime broker data. We return a free completeness read: which sections and data points you already have, and which are missing.
02
Data ingestion & reconciliation
As your authorized agent, we pull positions, NAV, borrowings, derivatives exposure, counterparty and liquidity data from your fund administrator, prime broker, and GL; reconcile to audited financials.
03
Grounded drafting
The required sections are drafted from your validated data and the Form PF rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
Aggregation logic is verified; every numeric field is cross-footed; the 72-hour clock is checked; any failure blocks release.
05
Specialist release
A licensed compliance expert reviews the exceptions and methodology calls and signs the release. Novel legal determinations escalate to securities counsel.
06
Delivery & submission
You receive the completed Form PF filing, audit trail, and examiner-ready binder. Your authorized officer submits via PFRD/FINRA. We provide submission support.
The bar we hold
Rigor you can measure.
100%
Specialist-released
No filing ships without a human compliance expert signature.
5 days
Standard SLA (annual)
From complete intake to released filing.
72 hours
Event-report SLA
From trigger identification to draft report.
4
Data-source reconciliation
Fund administrator, prime broker, GL, and audited financials — every applicable file.
Why FundLedger PF
Built to be the most thorough option a private fund adviser has.
Documentation-complete, by design
The deliverable is completeness itself — every required section and data point accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run data reconciliation as your clerical agent. We never provide legal advice, make investment decisions, or file without your authorization.
Engagement
Flat fee, per filing. No hourly billing, ever.
Simple, predictable, and aligned with a documentation standard — not a percentage of AUM.
- A free Data Gap Scan before you commit — see exactly what is missing.
- One flat fee per released Form PF filing; disclosed pass-through data-source fees.
- Optional fixed-fee attorney review for novel legal determinations.
- Optional Event-Report Monitoring Add-on for 72-hour trigger surveillance and draft preparation.
FAQ
Questions, answered precisely.
Is FundLedger PF a law firm?
No. FundLedger PF, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for novel legal determinations.
Do you file the Form PF on my behalf?
No. We prepare the complete filing and provide submission support, but your authorized officer must submit via PFRD/FINRA. We never file without your authorization.
What makes a filing 'complete'?
Completeness is defined by the Form PF instructions: all required sections present, data reconciled to audited financials, aggregation logic verified, and every numeric field cross-footed. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA for annual filings is five business days from complete intake to a specialist-released filing. Event reports are drafted within 72 hours of trigger identification. The free Gap Scan is returned much sooner.
How are you priced?
A flat fee per released filing, plus disclosed pass-through data-source costs. No hourly billing and no percentage of AUM.
See what's missing before it costs you a penalty.
Start with a free Data Gap Scan. Send your fund financials and administrator reports and we'll return a completeness read against every section of Form PF.
Documentation-completeness service · not legal advice · your authorized officer submits every filing.