Bank of America Merrill Lynch Hedge Fund Consulting - COOConnect

Bank of America Merrill Lynch 

Hedge Fund Consulting 

Overview of the Form PF 

Service Provider Landscape 

Revised May 2012

All information provided herein is for discussion purposes only, and is not intended to 

be nor should it be construed or used as investment, tax or legal advice. All recipients 

should consult with their legal counsel, and tax, financial and other advisors with 

respect to any information provided herein. Given the continuously evolving nature of 

the new regulations, hedge fund managers should be following the situation closely. 

As a result of the Dodd-Frank Act, the SEC has created a new regulatory filing for SECregistered 

investment advisors to hedge funds and other private funds: Form PF. With the 

data reported on Form PF, the SEC is gathering information to more actively monitor and 

track systemic risk across the private fund industry. Completing a Form PF filing can be a 

daunting task, especially for managers with minimal staff. As a result, a niche industry is 

rapidly emerging within the hedge fund service provider community to provide assistance. 

The purpose of this paper is to provide an overview of the Form PF service providers and 

their offerings, as of the date of this publication (May 2012). This is the second iteration 

of this survey. Given the rapid developments, we will be publishing updates periodically. 

Form PF represents the most significant regulatory requirement imposed to date on private fund 

advisors. Completing it will require an extensive data aggregation, normalization and reporting 

exercise for most managers. Requiring some 2,000 individual data points, the manager must 

identify and disclose information on a wide range of topics. 

The scope and frequency of filing, as well as specific sections, is dependent on the type and 

amount of an investment advisor’s Regulatory Assets Under Management (RAUM). Calculating 

Regulatory AUM is a new requirement and critical to properly understanding your filing obligations. 

Please consult your legal counsel to ensure all relevant assets are included in your calculation. 

Regulatory 

AUM 

Threshold 

Type 

of Fund 

Filing 

Frequency 

$150M All Annual 

$1B Liquidity Fund Quarterly 

$1.5B Hedge Fund Quarterly 

$5B Hedge Fund Quarterly 

$2B Private Equity Annual 

Due 

Date 

120 days after 

fiscal year end 

15 days after 

quarter end 

60 days after 

quarter end 

60 days after 

quarter end 

120 days after 

fiscal year end 

* Section 2a requires reporting aggregate data across all of the advisors’ hedge funds. 

A separate Section 2b must be completed for each qualifying hedge fund. 

Effective Date Required Sections 

Q4 2012 l 

1 2* 3 4 

Q4 2012 l l l 

Q4 2012 l l 

Q2 2012 l l 

Q4 2012 l l l 

Overview of the Form PF Service Provider Landscape 

3

Examples of Key Data Elements by Form PF Section 

Section 1 

• Regulatory AUM, gross and net asset value, and breakdown of managed accounts 

• Sources and levels of borrowing/leverage 

• Liability on Levels 1, 2 and 3 assets 

• Ownership and investor details 

Section 2 

• Usage of OTC and centrally cleared derivatives 

• Exposure and monthly turnover by asset class 

• Counterparties and posted collateral 

• Risk metrics 

Section 3 

• Side pocket and investor gate info 

• Investor liquidity 

• Portfolio liquidity by asset class 

Section 4 

4 May 2012 

• Applicable only to private equity funds, and therefore out of scope of this document 

Where Is the Data? 

The necessary data to complete Form PF is spread across fund administrators, prime brokers, 

counterparties, and a manager’s internal systems. 

Fund Administrators: Most advisers work with a third-party fund administrator to maintain their 

official books and records. As a result, it is advisable to source as much data as possible from 

the fund administrator. A fund administrator may have a substantial majority of the necessary 

data including: 

• Portfolio holding 

• Position detail and trade activity 

• Counterparty exposure 

• Pricing/valuation data 

• Investor data from the shareholder registry 

In addition, some fund administrators may calculate or be able to provide risk data as well.

Prime Brokers/Swap Counterparties: A fund’s prime brokers and swap counterparties can be 

the source of data on: 

• Borrowings and unencumbered cash 

• Financing terms 

• Mark-to-market counterparty exposure 

Internal Systems: Depending on the sophistication of a fund advisor and the complexity of the funds 

managed, risk calculations and aggregated data some may be sourced from internally operated 

and maintained systems. Typical source systems include: 

• Risk management systems 

• Portfolio management systems 

• Data warehouses 

Key Drivers of Complexity 

Form PF represents a new type of regulatory filing in that it reports activity at the investment 

manager level rather than the individual fund level. Since an investment manager may advise 

multiple funds or private pools of capital, the data must be normalized and aggregated across 

a wide range of disparate sources. Factors that impact the complexity of this exercise include: 

• Number of funds and/or separately managed accounts 

• Number of prime brokers (per fund or managed account) 

• Number of administrators 

• Asset classes traded by each fund 

Creating a Form PF Filing Program 

• Trading and clearing activity 

• Asset rehypothecation 

• Collateral posted 

As Form PF will need to be filed annually or quarterly, depending on a fund manager’s size and type, 

it is advisable to develop a defined and repeatable process. Below is an indicative project plan for 

those managers who will conduct their initial filing during Q1 2013. Each step is detailed on page 6. 

June 2012 July 2012 Aug. 2012 Sept. 2012 Oct. 2012 Nov. 2012 Dec. 2012 Jan. 2013 Feb. 2013 

1. Identify Reportable Entities and Data Sources 

2. Data Gap Analysis 

3. Data Collection and Normalization 

4. Data Aggregation and Form Population 

5. Test Runs 

6. Submit and Archive the Filing 

7. Update Disaster Recovery/Business Continuity Plan 


5

Once the initial filing has been completed, it is important to ensure the investment manager’s 

disaster recovery/business continuity plan is updated to include the Form PF filing process. 

1. Identify Reportable Entities and Data Sources: Take inventory of all funds and separately 

managed accounts advised by the manager. Note all prime brokers, counter-parties and fund 

administrators used. Also, meet with legal counsel to review and understand the applicable 

level of Form PF reporting requirements. 

2. Data Gap Analysis: Before answering any of the Form PF questions, it will be necessary 

to review each one and determine the specific source data necessary to derive the answer. 

This step will be most onerous during the initial filing. However, it should also be conducted 

at the start of each filing period to capture any new requirements or data sources. 

3. Data Collection and Normalization: Once the specific source data has been identified, it will 

need to be collected into a central repository. The data from disparate sources will then need 

to be normalized for consistency across the entire data set. The SEC has also created a new 

classification scheme for data to be used in Form PF. Categories including strategy, country, 

asset type and region have specific options. This classification scheme will likely be different 

from what the investment manager uses internally, so an extra mapping step may be necessary. 

4. Data Aggregation and Form Population: After the data is collected and normalized across 

reporting entities, it is then possible to aggregate that data into the composite values requested 

by the form and answering specific questions. This step may also involve performing risk calculations 

such as VaR and historical scenarios. Best practices in this step include an audit trail that captures 

inputs and decisions made in the normalization process, as it could be important to provide 

clarification to investors or the SEC at some point in the future. 

5. Test Runs: Creating a “test filing” prior to final submission will pinpoint the questions/sections 

where source data has not been completely captured or normalized. Repeat steps 2–5 as often 

as necessary until each question has been answered satisfactorily. 

6. Submit and Archive the Filing: Form PF must be submitted electronically to FINRA’s new PFRD 

(Private Fund Reporting Depository). Once submitted, the filing should be archived internally, as 

subsequent filings will require explanations on values that have changed between filing periods. 

7. Update Disaster Recovery/Business Continuity Plan: Once the initial filing has been completed, 

it is important to ensure the investment manager’s disaster recovery/business continuity plan 

is updated to include the Form PF filing process. 

6 May 2012

Who Can Help With Filing Form PF? 

As the deadline for the initial Form PF filings draws closer, many service providers are rolling 

out offerings to assist their private investment manager clients. The participants and offerings 

in this segment are evolving rapidly, but they can generally be grouped into three categories: 

Fund Administrators 

Form PF offerings from fund administrators come in two flavors: 

• Full Service: The “full service” fund administration Form PF offering will 

take data the administrator already has, combine it with additional data 

provided by the manager and other external sources, perform the aggregation, 

normalization and calculation steps, and submit the completed filing. 

• Extract Only: Alternatively, many fund administrators are choosing 

to provide their client with only an extract of the data they have. This extract 

can be combined with internal data or handed off to an external provider 

(e.g. third-party technology firm or data aggregator) to complete the filing. 

Technology Firms and Data Aggregators 

Many software firms catering to hedge funds have expanded their products to address 

the requirements of Form PF. Again, the technology offerings fall into two categories: 

• Data Aggregation Tools: Data aggregation tools typically take the form of a 

data warehouse which stores the relevant source data (trades, positions, prices, 

security information, classification categories, etc.) for each fund over time. 

• Workflow Tools: Workflow tools provide a project management context around 

the compiling of source data and answering each question in the form. These tools 

allow specific questions or sections to be assigned to individuals, track completion 

progress, and maintain an audit trail with supporting detail behind each answer. 

It is important to have a method for maintaining an audit trail 

and track the inputs and decisions that are used in each answer. 

Consulting Firms 

Several consulting firms are now prepared to assist managers in creating a repeatable process 

for completing and filing Form PF. These projects will include the initial analysis to determine 

where each input can be sourced from, normalizing the data across the various sources, and 

establishing the steps for using the data to answer each question. Some consulting firms offer 

their own software-based workflow tools to help clients manage the process. Others have formed 

partnerships with technology firms/data aggregators. Consulting firms active in this space range 

from the traditional “Big 4” management consulting firms to boutiques that specialize in working 

with alternative investment managers. 


7

Case Studies 

As illustrative examples, below are three case studies on fund managers of varying complexity and considerations. 

Simple Medium Complexity High Complexity 

Commingled Funds 

Number of Funds 

and/or Strategies 

2 2 3 

AUM (millions) 

Managed Accounts 

$100 $250 $1,000 

Number of Accounts 0 1 5 

AUM (millions) 

Regulatory AUM (millions) 

$ – $50 $150 

Long Market Value – 


$200 $500 $2,000 

Short Market Value – 


$200 $500 $2,000 

Borrow For Leverage – 


$100 $250 $1,000 

Long Market Value – 


$ – $100 $300 

Short Market Value – 


$ – $100 $300 

Borrow For Leverage – 


$ – $50 $150 

Total $500 $1,500 $5,750 

Number of Prime Brokers 2 3 3 

Number of Fund 

Administrators 

Filing Requirements 

1 2 3 

Filing Frequency Annually Quarterly Quarterly 

Initial Filing Deadline Q1 2013 Q1 2013 Q2 2012 

Strategy/Asset U.S. fundamental equity long/short Global convertible bond arbitrage with Global multi-strat; trades equities, 

Classes 

CBs, equities, equity options, CDS 

credit, futures, FX, listed and 

OTC derivatives, bank debt 

Key Considerations Note the impact of short balances 

and leverage on the Regulatory 

AUM calculation 

Must file Form PF since Regulatory AUM 

is greater than $150 million, even 

though AUM is only $100 million 

Potential Approaches If transaction volume is high, consider 

data warehouse-based solution 

If transaction volume is low, 

consider fund administrator or 

outsourced technology solution 

Estimated 

Cost Range 

8 May 2012 

Note the impact of short balances, 

leverage and managed account 

balances on Regulatory AUM 

Must file quarterly since 

Regulatory AUM is $1.5B 

With a single administrator for 

both the funds and the managed 

account, consider that particular 

administrator’s Form PF offering, 

if available and compatible 

Note the impact of short balances, 

leverage and managed account 

balances on Regulatory AUM 

Initial filing is 2012 since 

Regulatory AUM > $5B 

Complexity from product mix plus 

multiple prime brokers and fund admins 

Consider a full solution with: 

• Advanced multi-use workflow 

• A robust data warehouse 

• Potential consulting engagement 

$10,000 – $50,000 (single annual filing) $40,000 – $250,000 (annually) $250,000+ (one-time cost 

of warehouse installation 

and/or consulting engagement)

Service Provider Overview 

As the requirements and implications of Form PF become better understood, new participants 

are continuously entering the fledgling Form PF vendor/service provider industry, and their offerings 

are evolving. The data in the following service provider summaries is as of May 2012 and has 

been self-reported directly by the providers. Bank of America Merrill Lynch accepts no responsibility 

for any such data and cautions each investment manager to make proper inquiries of each vendor 

as to the accuracy of such information. The investment manager is reminded that it is ultimately 

responsible for timely and accurate completion of this filing. 

Fund Administrators, Technology Providers and Data Aggregators 

Topics to consider when evaluating a fund administrator, technology provider or data aggregator’s 

Form PF offering: 

• How similar is the advisor’s strategy/size/complexity to other Form PF 

clients serviced by the administrator or provider? 

• Will the solution accept and aggregate data provided by outside administrators? 

• Can the solution perform risk calculations, or require the results to be provided? 

• What people resources does the provider make available to help compile Form PF? 

• What workflow tools are provided to track progress and manage assignment of questions/sections? 

• Financial stability of the administrator or provider. 


Topics to consider when evaluating Consulting Firms: 

• How similar is the advisor’s strategy/size/complexity to the consulting firm’s other Form PF clients? 

• Does the firm have a Form PF-specific methodology? 

• What is the level of experience of the proposed project team with Form PF and related topics? 

• What systemized tools and/or calculators does the consulting firm provide? 

And manage assignment of questions/sections? 

• Ensure that the proposed Project Team is the team that comes to execute the project 

• Look to reduce the risk of cost overruns through fixed billing proposals 

How Can Bank of America Merrill Lynch Hedge Fund Consulting Help? 

As you prepare for Form PF, the Bank of America Merrill Lynch Hedge Fund Consulting team 

can assist in a number of ways: 

• Providing a framework and assistance with establishing a Form PF filing program 

• Reviewing applicable vendor/service provider offerings in the marketplace 

• Advising on best practices for sourcing and aggregating data 


9


The data in the above service provider summaries is as of May 2012 and has been self-reported directly by the providers. Bank of America Merrill Lynch accepts 

no responsibility for any such data and cautions each investment manager to make proper inquiries of each vendor as to the accuracy of such information. 

10 May 2012 

AIS Citco Fund Services 

Contact Info Firm Contact/Lead Name Scott Syracuse William Andreoni 

Email Address scott@aisgrp.com bandreoni@citco.com 

Phone Number 201.708.9741 610.232.1730 

Address 433 Hackensack Ave. 

Hackensack, NJ 07601 

Data Sources Import data from external fund administrator N/A Yes 

83 General Warren Blvd. 

Suite 200 

Malvern, PA 19355 

List of administrators tested as of May 1 N/A Not reported 

Administrators planned for integration in 2012 N/A Not reported 

Import data from prime broker or swap counterparties N/A Yes 

List of brokers tested as of May 1 N/A Not reported 

Brokers planned for integration in 2012 N/A Not reported 

Import data from risk tool or external risk vendor N/A Yes 

List of risk tools tested as of May 1 N/A Not reported 

Risk tools planned for integration in 2012 N/A Not reported 

Sources of pricing data N/A Major pricing vendors and 

some smaller vendors 

Allow export of data to client/external administrator/vendor Yes – provide data extract only Yes


GlobeOp HedgeServ Kaufman Rossin SEI SS&C 

Tony Glickman Julie McGlynn Josh Altchek SEI/James Cipriano Michael Megaw 

tglickma@globeop.com jmcglynn@hedgeserv.com jaltchek@krfs.com jcipriano@seic.com mmegaw@sscinc.com 

646.827.1834 212.920.3545 305.857.6734 610.676.1230 212.455.6333 

156 W. 56th Street 

New York, NY 10019 

1251 Ave. of the Americas 

21st Floor 


2699 South Bayshore Drive 

9th Floor 

Miami, FL 33133 

1 Freedom Valley Drive 

Oaks, PA 19456 

Yes Yes Yes Yes Yes 

All major administrators 

and many smaller ones 

N/A N/A SEI administrative clients – 

data loaded via predefined 

template (data warehouse) 

675 Third Avenue 


Accepts data files 

from any source 

Not reported N/A N/A Not reported Accepts data files 


Yes Yes N/A–source data is obtained 

from our reconciled systems, 

not from prime brokers 

All major prime brokers 

and many smaller ones 

Yes Not reported 

None N/A SEI administrative clients – 



Bank of America Merrill Lynch, 

Credit Suisse, Goldman 

Sachs, Morgan Stanley, 

UBS, J.P. Morgan, Bank of 

New York, NT State Street 



N/A All major brokers supported 

Yes Yes No Yes Yes 

GoRisk, RiskMetrics, 

MeasureRisk 

Any recognized risk service Novus, RiskMetrics, 

Investor Analytics, APT 

Reuters EJV, Reuters 

DataScope, Reuters Select 

Feed, Reuters LPC, Bloomberg 

BGN, Bloomberg BVAL, 

Markit, Fitch Solutions, CMA 

Datavision, IDC, Tullett Prebon, 

PricingDirect, RBS PriceSmart, 

Pluris, S&P, Houlihan Lokey, 

SuperDerivatives 

None N/A SEI administrative clients – 



Bloomberg, Reuters WM 

Company, Markit, CMA, Super 

Derivatives, Monis, IDC 



N/A Not reported Support for both SS&C 

proprietary risk system 

as well as all major 

external risk providers 

Various pricing vendors IDC, Bloomberg, Markit, 

Reuters, etc. 


All major pricing vendors 


11




12 May 2012 


Data Input Spreadsheet-based data import supported N/A Yes 

Graphical 

Workflow and 

Reporting 

Calculation 

Support 

Technical 

Infrastructure 

Web-based input supported N/A Yes 

Proprietary, enterprise system for data input N/A Yes 

Describe other data input mechanisms (if any) N/A Not reported 

Single/multi-user front-end N/A Multi-user 

Web-based or local client N/A Web-based 

Permissioning to specific questions/sections N/A Yes 

Question level locking N/A Yes 

Progress reporting and tracking (e.g., dashboard) N/A Yes 

Number of pre-built management reports N/A 10+ 

Ability to output Form PF in SEC-type format N/A Yes 

Drill down from an answer to position/trade level detail N/A Yes 

Audit trail with ability to modify supporting calculations N/A Yes 

Regulatory AUM N/A Yes 

Calculate “turnover” values based on transaction data N/A Yes 

Calculate “portfolio liquidity” based on transaction and market data N/A Yes 

Calculate VaR N/A Yes 

Calculate scenarios N/A Yes 

Describe other calculations supported N/A Yes 

Hosted, software as service or installed infrastructure N/A Hosted/SaaS 

Underlying database technology N/A Oracle 

Separate regulatory database N/A Yes 

Multi-tenant or separate instance for each client N/A Yes 

Customizable front-end N/A Yes 

Open reporting for generating ad hoc reports N/A Yes 

Resources Number of staff members dedicated to Form PF support N/A 40+ 

Technical support for third-party integration N/A Not reported 

CFA/accountant N/A Not reported 

Legal/regulatory advisory N/A Not reported 

Project consulting N/A Not reported






Not reported N/A N/A Not reported XML, Data feeds 

Multi-user Multi-user Multi-user Multi-user Multi-user 

Web-based Web-based Web-based Web-based Web-based 




58 Yes In process TBD 10+ reports and dashboards 




Yes Yes Yes No Yes 


Yes Yes No No Yes 



Not reported HedgeServ has the ability 

to support all Form PF 

required calculations. 

N/A Ability to use manager 

preferred or SEI calculations 

Duration, WAT, net/ 

gross performance 

Hosted/SaaS Hosted/SaaS Hosted/SaaS Hosted/SaaS Hosted/SaaS 

Sybase + Cognos SQL Server MySQL, SQL Server, 

Geneva Database 

SQL Server SQL Server 

Yes Yes No No Yes 

Yes Yes Multi-tenant Yes Yes 

Yes Yes In process Yes Yes 

No Yes No Yes Yes 

12 15 Filing status/client-specific Not supplied in detail. Over 25. 

3 4 7 Filing status/client-specific Not reported 


3 Using third-party advisor 1 Filing status/client-specific Not reported 



13


Cost/Pricing 

Model 

Affiliations/ 

Partnerships 



14 May 2012 


Per filing N/A Customizable 

BPS on AUM N/A No 

Project fee-based N/A Customizable 

Describe any other cost drivers/levers N/A N/A 

Firm name N/A Not reported 

Function/nature of service N/A Not reported 

Bundled offering or requires separate contract N/A Not reported



Customized for client 

depending on style, number 

of funds and counterparties 

$10K–$50K Generally $7,500 per filing TBD Not reported 

Not reported N/A N/A TBD Not reported 

Not reported Flat fee N/A TBD Not reported 

Risk data, funds and 

counterparties 

N/A Complexity and volume 

will affect fees 

TBD Not reported 

Not reported Advise Technologies N/A Not reported Not reported 

Not reported PW workbook and 

workflow tools 

Not reported Evaluated on a clientby-client 

basis 

N/A Not reported Not reported 

N/A Not reported Not reported 


15

Technology Firms 

and Data Aggregators 



16 May 2012 

Advise Technologies Black Mountain ConceptOne Data Agent 

Contact Info Firm Contact/Lead Name Doug Schwenk Brian Guarini Dan Connell Kelli Brown 

Email Address doug.schwenk@ 

advisetechnologies.com 

bguarini@ 

blackmountainsystems.com 

dan@conceptonellc.com kellibrown@ 

dataagent.com 

Phone Number 646.657.8406 646.400.0717 646.840.4996 415.229.9190 

Address 10 E. 39th St., Ste. 925-D 


Data Sources Import data from external 

fund administrator 

List of administrators 

tested as of May 1 

Administrators planned 

for integration in 2012 

Import data from prime broker 

or swap counterparties 

List of brokers tested 

as of May 1 

Brokers planned for 

integration in 2012 

1001 Ave. of Americas 


527 Madison Avenue 


Yes Yes Yes Yes 

7 State Street, Bank of 

New York, LaCrosse 

Approx. 35 GlobeOp and as 

directed by customers 

Citco, SEI, AIS, MSFS, 

Admiral, CACEIS 

We have taken data 

for existing reporting 

services from the 

majority of Fund 

Administrators to date 


5 Credit Suisse, Deutsche 

Bank, Goldman Sachs 

We have taken data 

for existing reporting 

services from the 

majority of Prime 

Brokers to date 

Approx. 15 As directed by customers All TBD 

2000 Hearst Ave., Ste. 304 

Berkeley, CA 94709 

16 

TBD 

Various



HazelTree Indus Valley Partners Paladyne MIK Fund Solutions MSCI RiskMetrics Viteos Fund Services 

Stephen Casner Gurvinder Singh Bill Kelly Marshall Saffer Ron Papanek Jonathan White 

scasner@hazeltree.com sales@ivp.in bkelly@paladyne.com msaffer@mikfs.com ron.papanek@msci.com jonathan.white@ 

viteos.com 

646.837.9450 201.984.1045 646.214.3743 212.468.2002 212.981.1085 646.861.3409 x. 202 

150 W. 30th St., 18th Fl. 


1350 Broadway, Ste. 601 


420 Lexington Avenue, 


1633 Broadway, 28th Fl. 


Yes Yes Yes Yes Yes Yes 

Morgan Stanley 

Fund Services 

GlobeOp, Citco, DB 

Fund Services, BNP 

Citco, State Street, 

GlobeOps, LaCrosse 

Paladyne is currently 

working with four fund 

administrators to deliver 

a Form PF solution to 

their clients for the June 

30 filing. Paladyne has 

developed standard 

adaptors for pulling data 

from third-party systems 

(e.g., Advent Geneva, 

RiskMetrics, etc.). 

Most fund administrators 

leverage Advent Geneva 

which would be a 

standard extract. 

MSFS, HedgeServ, NT Four administrators to 

be discussed at a later 

date. Paladyne is selling 

its Form PF solution to 

fund administrators, 

but it is also available 

for use by the individual 

fund managers as well. 

441 Lexington Ave., 


Not reported All major administrators Currently seven dynamic 

mapping tool allows 

for data integration 

with any data source 

Not reported Not reported Client-driven 


Morgan Stanley, 

Goldman Sachs, J.P. 

Morgan, Credit Suisse, 

UBS, Deutsche Bank, 

Barclays, Citigroup, 

Fidelity, Bank of America 

Merrill Lynch, BNP 

Morgan Stanley, 

Goldman Sachs, 

Deutsche Bank, Credit 

Suisse, Bank of America 

Merrill Lynch, Fidelity 

Paladyne has created 

a standard set of 

templates for gathering 

all data required in 

Form PF. Paladyne may 

accept any generic 

broker feed or may 

work with brokers to 

comply with Paladyne’s 

standard template. 

Not reported Multiple existing All major prime brokers 

and counterparties. 

Most second-tier PBs 

and CPs. Existing 

integration through 

fund administration and 

middle office business. 

Any ISDA counterparty MSFS, HedgeServ, NT Client-driven Not reported Not reported 


17



Data Sources Import data from risk tool 

or external risk vendor 



18 May 2012 

List of risk tools tested 

as of May 1 

Risk tools planned for 

integration in 2012 



4 N/A Not reported MSCI RiskMetrics, 

Nirvana 

Approx. 8 R2 Not reported TBD 

Sources of pricing data 3 Bloomberg, Markit, 

Thomson Reuters, 

LPC, IDC 

Allow export of data to client/ 

external administrator/vendor 

Data Input Spreadsheet-based data 

import supported 

Graphical 

Workflow and 

Reporting 

Multiple market 

data providers 



Web-based input supported Yes Yes Yes Yes 

Proprietary, enterprise 

system for data input 

Describe other data input 

mechanisms (if any) 


XML, CSV, ETL, API, Link 

to Spreadsheet, Custom 

Our product has an 

incredibly open interface 

to import data from 

virtually any format 

and any technology 

Bloomberg, IDC, Reuters, 

Markit, and others 

Not reported Comprehensive suite 

of ETL services 

Single/multi-user front-end Multi-user Multi-user Multi-user Multi-users internally 

and externally 

Web-based or local client Both Both Web-based Web-based 

Permissioning to specific 

questions/sections 


Question level locking Yes Yes Yes Yes 

Progress reporting and 

tracking (e.g., dashboard) 

Number of pre-built 

management reports 

Ability to output Form PF 

in SEC-type format 

Drill down from an answer to 

position/trade level detail 


11 Customized on a 

client-by-client basis 

Yes 12 


Yes Yes Yes Yes





Algorithmics Risk Metrics, Imagine, 

Front Arena, R2 

Imagine, Risk 

Metrics, MSCI 

Bloomberg, SunGard Bloomberg, Reuters, 

Factset, IDC, Markit, 

Adaptor Tool available 

to on-board others 

Paladyne has developed 

a standard adaptor with 

Risk Metrics or may 

take a generic risk file 

from a client or provide 

a client with a standard 

risk template to be 

populated by the client. 

Not reported RiskMetrics Algorithmics 

Not reported Client-driven Not reported RiskMetrics RiskMetrics, Imagine, 

Investor Analytics 

Paladyne supports all 

sources of pricing data. 

Any source 50 vendors; Markit, 

LPC, Reuters, etc. 




Yes No Yes Yes No Yes 

Direct import from 

HazelTree datastore 

Not reported Paladyne has developed a 

standard set of templates 

for collecting all Form PF 

data and has a proprietary 

ETL tool for managing 

all external data. 

Bloomberg, IDC, Markit 

Not reported XML, CSV, RM3D Manual (if required) 

Multi-user Multi-user Multi-user Multi-User Multi-user Yes 

Other Web-based Web-based Web-based Web-based Web-based 



Yes Yes Yes Yes Not reported No 

2 10 Paladyne has developed a 

set of data views to support 

all calculations in Form PF. 

Not reported Not reported Currently five, 

unlimited (custom 

report generation) 


No Yes Yes Yes Yes Yes 


19



Calculation 

Support 

Technical 

Infrastructure 



20 May 2012 

Audit trail with ability to modify 

supporting calculations 



Regulatory AUM Yes Yes No Yes 

Calculate “turnover” values 

based on transaction data 

Calculate “portfolio liquidity” 

based on transaction 

and market data 



Calculate VaR No No Yes Yes 

Calculate scenarios No Yes Yes Yes 

Describe other calculations 

supported 

Hosted, software as service 

or installed infrastructure 

All others in Form PF We support Yield, 

DV01, Duration, STW, 

as well all Excelbased 

calculations, 

and a customizable 

library of functions 

Client-specific 

calculations depending 

on pricing policies 

of a given client; 

complete aggregation 

Local installation Both Both Both 

Customizable 

Underlying database technology SQL Server or Oracle SQL Server SQL Server SQL Server 

Separate regulatory database Yes Yes Yes Yes 

Multi-tenant or separate 

instance for each client 


Customizable front-end Yes Yes Yes Yes 

Open reporting for 

generating ad hoc reports 

Resources Number of staff members 

dedicated to Form PF support 

Technical support for 

third-party integration 


27 1 35+ 22 

12 5 10 10 

CFA/accountant 2 0 10 0 

Legal/regulatory advisory 4 0 10 1 

Project consulting 3 20 5 5





Yes No Yes Yes Yes Yes 

Yes Yes Yes Yes No No 

Yes Yes Yes Yes Yes No 

No No No No Yes Yes (Algorithmics) 

No No No No Yes Yes (Algorithmics) 

Duration, security 

level ratios 

Ability to import Paladyne supports all 

calculations in Form PF 

with the exception of risk. 

Paladyne would require a 

third-party data source for 

calculated risk information. 

All calculations and 

static data are stored 

historically in the Paladyne 

data warehouse and 

may be extracted into 

the Form PF GUI, XML 

format, or Excel-based 

on client requirements. 

Not reported Complete portfolio 

risk statistics and 

scenario analysis 

Full custom derivation/ 

calculation support at 

the point of import. 

Custom calculation 

on Regulatory 

AUM, GAV, etc. 

Both Local Installation Hosted/SaaS Local Installation Hosted/SaaS Software as a service 

SQL Server SQL Server Microsoft SQL Server Oracle Not reported 

Yes No No Yes No No 

Yes No Yes Yes Yes Separate instance 

No Yes Yes Yes Yes No 


20 10 10 4 developers for just 

Form PF experience 

6 10 

15 5 7 47 developers 6 N/A 

1 0 3 Not reported Not reported 10 

0 0 0 Not reported Not reported N/A 

4 5 3 One project 

lead dedicated 

10+ 4 


21



Cost/Pricing 

Model 

Affiliations/ 

Partnerships 



22 May 2012 


Per Filing $0 N/A 25,000-100,000 $5,000 to $10,000 

per filing 

BPS on AUM $0 N/A flexible N/A 

Project fee-based In some cases Time and materials yes N/A 

Describe any other 

cost drivers/levers 

Per install Installation of 

Everest product 

Firm Name Ryan Associates; 

HazelTree Fund Services; 

Paladyne Systems 

Function/Nature of service Systems integration and 

data loading toolkit; 

integration with 

HazelTree data 

warehouse; 

hosting on Paladyne 

platform and integration 

with Paladyne data 

warehouse 

Bundled offering or requires 

separate contract 

Deployed or hosted; 

quality of data; number 

of assumptions 

and other custom 

calculations; number 

of data sources 

Set-up fees ranging from 

approximately $5K–$25K 

depending on complexity 

N/A Rothstein Kass Yes; two top 

tier compliance 

consulting firms. 

Formal agreements 

to be finalized. 

N/A Regulatory advisory 

services 

Separate contract N/A Either bundled or 

separate contract 

Compliance 

consulting services 

Separate contract




No cost per filing Not reported N/A N/A Not reported $15K–$25K per filing 

Costs are not 

based on AUM 

Monthly fee based on 

counterparties and users 

Standalone vs. 

multi-user system 

Not reported N/A N/A Not reported N/A 

Not reported Each implementation 

would have a services and 

license fee component 

to overall pricing. 

Annual ($25K–$40K) 

depending on 

sections applicable 

Paladyne charges an 

annual support fee and 

a license fee for various 

product components. 

In addition, Paladyne 

sub-licenses advice as 

an optional component 

of the overall solution 

which would be an 

additional charge. 

Time and material cost 

for implementation 

Have to install 

the warehouse 

Not reported $80K–$150K for full 

setup of initial filing 

Not reported None 

Not reported Not reported Advise Technologies N/A Advise Technologies, 

MIK, Red Swan, 

Indus Valley, Paladyne 

Not reported Not reported Web-based instance 

of Form PF 

Not reported Not reported Sub-licensing 

arrangement allows 

for a single contract 

with Paladyne. 

Algorithmics 

N/A Risk Analytics Risk services/reporting 

N/A Both Additional charge for risk 

data through Viteos. 


23




24 May 2012 

ACA Compliance Deloitte Ernst & Young 

Contact Info Firm Contact/Lead Name Jack Rader, Jessica Huelbig Karl Ehrsam Samer Ojjeh, Anita Bafna 

Deliverables Form PF Project 

Methodology 

Email Address jrader@acacompliancegroup.com 

jhuelbig@acacompliancegroup.com 

kehrsam@deloitte.com samer.ojjeh@ey.com 

anita.bafna@ey.com 

Phone Number 973.631.1085 212.436.3153 212.773.6486 

212.773.3938 

Address 2180 Headquarters Plaza 

East Tower, Suite 205 

Morristown, NJ 07960 

Analysis of required data 

inputs and sources for 

each section/question 

1 World Financial Center 


N/A Deloitte breaks down projects into 

four basic phases: Requirements 

Analysis, Gap Assessment, Solution 

Design, and Implementation. 

The method ultimately chosen 

depends largely on client need 

and goals, particularly if they are 

seeking a more strategic solution 

that addresses challenges related 

not only to Form PF, but also to 

provide consistency of data with 

other data and reporting needs 

(e.g., Form ADV, international 

large position disclosure, 13F/G 

reporting, marketing, client 

transparency reporting) 

N/A Deloitte will work with your legal 

counsel to perform an analysis 

of data inputs that are available 

from existing client systems and 

those that will need to be enriched 

from outside or other sources. 

5 Times Square 


Ernst & Young has tailored its regulatory 

reporting methodology to apply to Form PF 

reporting. We work closely with our clients to 

determine scope of services and customize our 

approach, but our standard approach to Form 

PF reporting model consists of the following 

phases: survey and planning, data analysis, 

solution design and implementation assistance. 

In addition we can introduce and leverage many 

of our Form PF accelerators (Fund Scoping 

Template, Fund Shadow Filer, Form PF Data 

Dictionary, Baseline Plan, Form PF reporting 

flows, etc.) to quickly kick off the initiative. 

Survey and Planning: During this phase, we 

assist our clients to determine eligible fund 

population and applicable Form PF sections, 

documentation including Form PF assumptions, 

construct Form PF data dictionary and codevelop 

high-level implementation roadmap 

related to any tactical or strategic solution 

including vendor selection activities. 

Data Analysis: In parallel, we work with 

our clients to conduct a rapid current state 

assessment and data gathering to understand 

data sourcing with an aim of identifying gaps 

and applicable reconciliation. 

Solution Design: Assist with the design and 

development of data aggregation processes, 

workflows, reporting processes and controls, 

calculations and mock reporting, vendor 

integration (as applicable). 

Implementation assistance: Assist with mock 

filing, Form PF completion, review and filing. 

Manage data sourcing, mapping 

and verification from multiple 

sources, standardization of data 

dictionary, design of the workflow, 

definition and review of calculations


Gravitas NorthPoint Solutions Rothstein Kass Sindex Financial WTP Advisors 

Timothy Hamel NorthPoint Solutions Gary S. Kaminsky, Principal Michael Scully Ilicia Silverman 

thamel@ 

gravitastechnology.com 

infous@northps.com gkaminsky@rkco.com mscully@ 

sindexsystems.com 

212.607.8243 212.819.1700 917.438.3648 646.291.6163 914.733.3362 

917.655.0051 

Gravitas BCS first 

defines the firm’s 

initiative based 

on specific form 

requirements, assigning 

responsibilities to a 

working group. Once 

established, a formal 

project plan is written to 

organize data mapping 

and aggregation. 

Gravitas BCS gap 

analysis focuses on 

making connections 

between disparate data 

and a final, reportable 

product. Mapping each 

section through staging 

tables for calculations 

and importing allows for 

a reliable, automatable 

filing process. 

130 West 42nd St., 


Project plan coupled 

with the solution’s 

filing wizard. 

Yes, through professional 

service engagement. 

1350 Ave. of the Americas 


Rothstein Kass Business 

Advisory Services, LLC (RKBAS) 

approaches Form PF as an 

exercise in regulatory enterprise 

risk management (ERM). RKBAS 

has constructed a four phase 

approach for developing an 

enterprise risk management 

infrastructure which will 

facilitate compliance with Form 

PF as well as other third-party 

reporting and disclosures: Phase 

I – Discovery (identification 

of reporting funds and their 

obligations including assistance 

with calculation of Regulatory 

Assets Under Management); 

Phase II – Data Mapping, 

Analysis and Interpretation; 

Phase III – Filing Review; and 

Phase IV – ERM Benchmarking. 

In addition to conducting 

a customized data 

mapping and gap 

analysis for each 

required data input, 

RKBAS will assist in 

the normalization, 

aggregation and 

enrichment of 

adviser, fund and 

position level data. 

Sindex’s staff has taken 

its project management 

methodology 

successfully used 

for complex datadriven 

initiatives, 

such as portfolio 

management systems, 

security master, order 

management systems, 

data warehouse 

and reporting 

implementations, 

and customized 

it for adaption to 

Form PF needs. 

Sindex has reviewed, 

organized and 

documented the 

more than 1,700 data 

elements that are 

included in preparing 

the Form PF filing. 

ilicia.silverman@wtpadvisors.com 

One North Broadway 

White Plains, NY 10601 

Working off of our comprehensive matrix of 

Form PF to corresponding data sources, WTP 

conducts a discovery diagnostic where we take 

an inventory of your data and where it resides 

(service providers vs. internal systems). We then 

prepare a Form PF blueprint comprised of a 

diagnostic report with full gap analysis, preliminary 

Form PF outline and recommendations. 

Leveraging our subject matter expertise, we provide 

full data discovery and analysis for each question 

on the form. This includes: identifying the sources, 

normalizing and aggregating the data (including 

performing additional calculations if required) and full 

mapping into the appropriate sections/questions. 


25


Deliverables Form PF specific minitools 

to accelerate 

and support progress 



26 May 2012 

Filing/submission 

to SEC via PFRA 


N/A We will utilize our Gap Assessment 

Template, Solution Assessment 

Framework, Planning and Data 

Analytics Tools, and Operating 

Model templates to accelerate 

progress with Form PF. 

N/A Deloitte will not file Form PF on 

behalf of a client, but will work 

closely with our clients to develop 

process- and technology-oriented 

solutions that will create repeatable 

and predictable outputs for Form PF. 

Customizable Form PF data 

dictionary for line-by-line Form PF 

data identification for each data 

point including data sources and 

calculation, central location for data 

element characteristics and tracking 

progress on each data element. 

Fund Scoping template that follows 

a multi-step Fund categorization 

process to help prioritize the filings 

along with sections to be filed and 

other details. 

Data Element Matrix: Organizes data 

mapping and calculations 

Shadow Filer: Leverages sources 

and uses of data listed in Data 

Element Matrix to test system data 

extracts for Form PF reporting, 

Baseline Form PF plan and 

Baseline Form PF reporting flow 

EY does not directly file the form 

with the SEC but works with 

vendors and clients to ensure 

smooth vendor integration, 

form accuracy and assumptions 

documentation before filing.



Formal workflow and 

initiative, an electronic 

Form PF filing application 

(third party), assistance 

with form calculations. 

Gravitas currently 

works with industryleading 

technology 

providers who have 

produced electronic 

filing applications. 

Gravitas BCS will see 

the client through the 

electronic process 

once it is completely 

defined by the SEC. 

Data management tools, 

data enrichment tools, 

aggregation engine, 

task flow engine and 

status dashboard. A VaR 

calculator, and stress 

test engine is available 

as an additional module. 

RKBAS utilizes a 

compliance and risk 

management tool which 

stores the client’s 

methodologies for 

answering each question 

in Form PF (provided 

as an approval audit trail 

and links to underlying 

data sets). Other 

regulatory filings can be 

built on to this platform 

to enable alignment of 

all third-party reporting 

and disclosures. 

Yes RKBAS available to 

assist in file submission. 

Sindex can either 

leverage systems the 

client has in place for 

calculating derived 

numbers (performance, 

VaR, etc.), or can utilize 

its own tools where the 

client may not have the 

capability in-house 

There are multiple 

software offerings in the 

marketplace designed 

to take finalized data 

input and format 

the filing to SEC 

specifications; we can 

assist in the selection 

and implementation 

of an appropriate tool 

from the marketplace 

if the client has not 

done so already 

“Mini tools” include: a customizable user dashboard, 

comprehensive review and approval workflow 

management, full audit trail and reporting, 

customizable security settings, ability to attach and 

store supporting documentation, a comprehensive 

calculation engine for form requirements, and an 

enterprise scale ETL component for data mapping. 

We support full XML integration for automated 

upload/filing capabilities to the SEC. 


27




28 May 2012 


Services Project Management N/A We can manage the overall Form PF 

project effort, from requirements 

through implementation (for 

non-attest client relationships) 

Subject matter experts 

(legal, CPA, CFA, etc.) 

ACA provides unparalleled regulatory 

compliance consulting to its clients, including 

investment advisers and private fund managers. 

ACA specializes in offering customized 

client-specific solutions designed to assist 

firms as they build and maintain best practice 

compliance programs. ACA bases these 

solutions on its unique insights into current 

regulatory focus areas, including Form PF filing 

requirements. 

ACA can assist clients in determining if and when 

they need to file Form PF and what section(s) 

of Form PF must be completed. Among other 

things, ACA can help to interpret specific filing 

questions based on its industry knowledge. 

Staff Augmentation Dedicated consultant for each 

ACA client supported by ACA’s 

regulatory filings team. 

Cost structure ACA is not offering a standalone 

Form PF filing solution. Rather, 

ACA will assist its clients with the 

application and interpretation of 

the Form PF requirements. ACA’s 

consulting related to Form PF is 

either included as part of the current 

consulting agreement with clients 

or offered on an hourly basis. 

Deloitte’s regulatory consulting 

resources and experience are 

global and span the alternative 

investments industry, including 

private equity funds, hedge funds 

and industry service providers. 

We bring regulatory reporting 

methodologies and leading 

practice insight to the challenges 

of new regulatory reporting 

requirements, such as Form PF. 

Deloitte can provide resources 

of varying skill sets to address 

the individual needs of each of 

our clients, whether regulatory, 

technology, industry, or other 

required resources. 

We charge on a time and 

materials basis as estimated 

for each client engagement. 

We provide program/project management 

assistance through the entire lifecycle of your 

Form PF reporting project. We can quickly assist 

you in mobilizing a multi-dimensional team from 

finance, operations, compliance and technology 

Apply proven approach to current and future 

state assessments, including processes 

and data flows, resourcing plan, data 

architecture, and implementation roadmap. 

Subject matter experts including 

asset management and regulatory 

reporting advisors, CPAs, CFAs, 

former SEC examiners, compliance 

and risk specialists, data and 

solution architects and analysts 

with significant years of experience 

Provide subject matter experts, 

project management professionals, 

risk and compliance professionals, 

data and solution integration 

architects and analysts 

Time and materials basis 

charged. Rates and references 

available on request.



On- and off-site project 

management team. 

Gravitas Managing 

Director Mark Seaman is 

responsible for providing 

high-end business 

consulting services with 

respect to software 

platform integration 

and best business 

practices for front, 

middle and back office 

operational workflow 

Timothy Hamel is 

responsible for 

business consulting 

regarding Form PF. 

Project undertaken 

on T&M, fixed cost 

and capped basis 

as determined by 

engagement. Typical 

fee range is between 

$100–$350/hour based 

on level of consultant. 

Available 

Available, assist 

with classification 

and aggregation. 

Available for the 

duration of the project 

Hourly per project, 

rates depend on level of 

professional services. 

Project management with 

RKBAS begins with advising 

on key Form PF issues and 

responsibilities as well as 

providing a tailored Gantt Chart 

to manage project completion 

and efficiency. RKBAS will 

“quarterback” your Form PF 

process by assisting with 

full-integration of internal 

and external resources, 

including legal counsel and 

technology providers. 

RKBAS engagement 

teams are equipped with 

CPAs, CFAs, MBAs and 

JDs, as well as former 

fund CFOs, CCOs, and 

COOs. RKBAS’s Form PF 

experts are available to 

provide interpretation 

of Form PF questions. 

Engagement teams 

are comprised of staff, 

managers and principals 

and are customized 

to meet the specific 

needs of the client. 

Each engagement team 

is overseen by Gary S. 

Kaminsky, Principal, 

former SEC enforcement 

attorney, CCO and 

hedge fund manager. 

We charge on a time 

and materials basis 

(initial retainer may be 

required). Note that 

RKBAS has developed 

a phased approach that 

directly correlates to 

time and deliverables. 

Sindex’s staff has an 

average of 15 years 

of financial industry 

experience, include 

project management 

of complex datadriven 

initiatives, 

such as portfolio 

management systems 

implementations, data 

warehouse and reporting 

implementations, etc. 

With our long-term 

hedge fund consulting 

practice, we have 

expertise on all the data 

components that make 

up the Form PF, whether 

it be shareholder 

data, performance, 

portfolio accounting, 

security master, risk, 

derivatives or leverage. 

Our staff’s expertise 

in automation and 

reconciliation can help 

reduce the need for 

staff augmentation; 

we do not provide the 

service ourselves, 

but our experience in 

documentation and 

training can help you 

leverage the temporary 

workforce more 

efficiently if needed 

Sindex bills at an 

hourly rate and will 

work with clients to 

control cost with careful 

resource planning 

End to end project management from hardware 

and software set up, data discovery analysis and 

preparation, data integration and automation, 

process consulting, filing support services 

and compliance support services. There is 

a complete solution knowledge transfer so 

client can be self-sufficient post project. 

Subject matter expertise for all aspects 

of the engagement including certified 

software professionals, former hedge 

fund COOs and CFOs, CPAs, CFAs, MBAs 

and former CCOs and legal counsel. 

Comprehensive project resources as well as staff 

augmentation during and post-project are available. 

You have complete access to our consulting business 

including our outsourced COO/CFO business 

team of experienced operational and financial 

experts as well as compliance consultants, legal 

professionals and a technology support team. 

Rates and references available upon request. 


29


Affiliations/ 

Partnerships 



30 May 2012 


Firm Name ACA is referring its clients to a 

select number of third-party service 

providers who offer Form PF filing 

solutions. ACA clients are eligible to 

receive a discount from certain of 

these third-party service providers 

N/A Vendor agnostic but we collaborate 

with several vendors that provide 

Form PF solutions/components 

Function/nature of service N/A N/A End-to-end Form PF solution 

providers, data aggregation and 

data warehouse specialists, and 

risk calculations providers 

Bundled offering or 

requires separate contract 

N/A N/A Bundled offerings and 

separate contract offerings



Gravitas—Consulting 

Services Division 

Consulting services 

to assist managers 

in analyzing Form PF 

requirements, mapping 

information from data 

sources, selecting/ 

implementing technology 

solution and establishing 

operating procedures 

to complete the form 

on an ongoing basis. 

Separate contract 

dependent on scope. 

N/A N/A N/A WTP—CheckPoint 

Consulting, LLC 

N/A N/A N/A Form PF reporting; 

architecture planning; 

software installation; 

support team setup; 

management/investor 

reporting; executive 

dashboards; product 

implementation 

and customization; 

requirements and design 

planning; deployment 

support; data 

integration specialists 

Requires separate 

contract 

N/A N/A Included in our 

standard offering. 

Compliance Consulting 

Solutions, LLC 

Compliance program 

development and 

on-going compliance 

support; SEC and state 

registration; annual 

compliance program 

reviews and compliance 

training; AML compliance 

monitoring; compliance 

manual development; 

trade surveillance and 

monitoring 

portfolio and investment 

guideline monitoring 

regulatory filings 

including Form ADV 

and Form PF; marketing 

material review; brokerdealer 

compliance 

support; assistance with 

regulatory examinations 

and mock examinations; 

business continuity plan 

development and testing 

Separate contract. 


31

Contact Us 

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contact the Hedge Fund Consulting Team at Bank of America Merrill Lynch. Our contact details are below—we look 

forward to hearing from you. 

Cary Goldstein Chris Throop 

+1.646.855.4029 +1.646.855.0612 

cary.goldstein@baml.com chris.throop@baml.com 

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