1 min read
SEC and CFTC Propose Major Form PF Overhaul: What Private Fund Managers Need to Know
If you manage a private fund, you've spent years building compliance infrastructure around Form PF, the confidential reporting form that the SEC and...
7 min read
Greg Farrington
:
July 14, 2026
We've spent the better part of two decades helping investment managers launch and scale. Across our team, we have advised on or supported the formation of more than 1,000 entities, including hedge funds, private equity firms, registered investment advisers, family offices, and the operating businesses around them. The pattern that repeats across nearly every successful launch is the same. The firms that make it past their first institutional capital raise, their first audit, and their first SEC exam, all built the operating foundation for the business they intended to become, before they needed it.
The firms that struggle often take the opposite approach. They focus on raising capital and gathering assets under management as quickly as possible, then attempt to backfill the operational infrastructure while executing their investment strategy. That approach can work for a while, until it doesn't.
This is the message we share with every emerging manager.
Launching an investment manager requires building three legal entities in parallel: the fund, the general partner, and the management company. Each has its own structure, governing documents, regulatory considerations, and operational requirements. Getting those pieces right is important, but they are only the starting point.
The harder work is what sits underneath. The operating foundation has to be ready to run from Day One and built to scale as the firm grows. That is the difference between launching a fund and launching a firm.
In our experience, the foundation comes down to four areas that every emerging manager should address before they begin managing capital.
The legal structure decisions made at launch tend to stay with the firm. It is critical to work with an experienced law firm that understands the nuances of your strategy and the underlying characteristics of the targeted investors.
The fund, general partner, and the management company all need to be structured correctly. Registration status needs to be clear. Exempt registered advisor (ERA), registered investment advisor (RIA), state filings, Commodity Futures Trading Commission (CFTC) considerations where applicable. None of this should be handled casually or out of sequence. Registrations that should have happened earlier, or filings that should have been coordinated with counsel, create work later that could have been avoided up front.
An often-overlooked consideration for founders is how the General Partner (GP) is structured from a gifting, trust, and estate planning perspective. In the right circumstances, carving out a portion of the GP interest for family members or trusts as part of an estate planning strategy, before the firm experiences significant appreciation in value, can create meaningful tax and wealth transfer benefits. Planning early, while the GP has a lower valuation, may help maximize the effectiveness of these strategies.
Service provider selection is one of the most consequential decisions a launch team makes, and it is one of the easiest to rush. A fund administrator that does not understand your strategy, counsel that has not seen your structure before, a prime brokerage relationship priced on incorrect assets under management (AUM) or trading strategy, or an order management system (OMS) / portfolio management system (PMS) system that is limited in functionality, can create cost and friction for years.
The work is not just picking names off a list. It is comparing alternatives, negotiating terms, diligencing the relationship, and making sure onboarding happens in the right way.
We treat vendor selection as an operating decision, not an administrative task
The finance function needs to work before anyone asks whether it works.
That means books and records that hold up under an audit. Reporting that is accurate and timely. A Chief Financial Officer (CFO) function that can support both the management company and the fund as well as responding to investor inquiries. Tax planning that happens before structures are locked in.
None of this is easier to fix later.
For most emerging managers, the right answer at launch is not a full finance department. It is an outsourced CFO and accounting function that can scale with the firm. The same is often true for human resources (HR). That keeps fixed costs aligned with AUM during the period when fixed costs can make or break the management company.
Operations are easy to underestimate because, when they work, no one talks about them.
Close processes. Reporting calendars. Compliance administration. Process documentation. Internal controls. Trade capture. Allocations. Reconciliations, NAV oversight. Counterparty coordination.
These are not glamorous functions. But when something breaks, they become the only thing investors want to discuss.
Institutional allocators treat operational and compliance infrastructure as a signal of how seriously the firm is being run. They should.
Most first-time managers underestimate the timeline.
Once the operational pieces are mapped, the next question is how long it all takes. A first-time manager often underestimates the answer. A realistic launch typically takes six to twelve months from the decision to launch, depending on strategy, structure, initial seed capital, regulatory path, and how much work can happen in parallel.
The first phase is structural and operational buildout: entity formation, registration filings, counsel engagement, tax structuring, negotiating seed capital, developing a budget, service provider selection, fund administrator onboarding, prime brokerage account opening, bank account setup, compliance program design, and books and records infrastructure. The work compounds, service provider negotiation, in particular, takes longer than most teams expect.
The final stretch is all about pre-launch readiness: operational due diligence (ODD) materials, compliance-approved marketing documents, and final validation of the operating model. The smoothest launches we see are the ones where the team has done the work to be ready before the first allocation conversation, not during it.
Once the first trade is executed, the operating model gets tested in practice. Close processes, reporting cadence, the compliance program, and investor communications all move from planning to execution. Most of the issues that surface in the first year are not surprises. They are gaps that could have been identified and addressed during the pre-launch phase.
Alongside the timeline, the other question every emerging manager asks is what it costs to operate the business. The answer is usually more than most teams model initially.
The fund generates management fees and performance fees. The management company bears the cost of running the firm: salaries, technology, compliance, audit, legal, insurance, rent, and the infrastructure to support growth. Those two sides need to balance, and the gap in the early years is often larger than expected. Building a realistic budget for both, with conservative AUM ramp assumptions, is part of what separates the launches that survive year one from the launches that do not.
The good news is that the cost of operating infrastructure has decreased over the past five years. Outsourced CFO support, fractional HR, middle office and trade operations, regulatory and compliance, and integrated service platforms allow emerging managers to build the right foundation without carrying the full cost of an internal team on Day One. That gives managers a more flexible way to scale: fixed monthly costs that grow with the firm, rather than permanent hires that add pressure during the years when every fixed cost matters. This is the model we recommend to emerging managers thinking through launch economics today.
A few patterns show up so consistently that we treat them as warning signs.
The first is underestimating the gap between launch capital and operating burn. Founders tend to model fund economics carefully and assume the management company will take care of itself. In practice, salaries, benefits, technology, compliance fees, audit, legal, insurance, rent, and other operating costs add up quickly. We have seen otherwise capable teams give up equity, take outside investments, or change strategy because the management company ran out of runway before the business reached scale.
The second is treating service providers as commodities. You get what you pay for. The cost of a wrong relationship is rarely visible at signing. It typically shows up later through reporting friction, operational rework, service issues, and lost time when the firm can least afford it.
The third is waiting too long to think about ODD, the review process institutional investors undertake before they allocate capital. They evaluate operations, controls, service providers, compliance, and infrastructure independently of the investment strategy. A firm that starts preparing for ODD only after investor questions arrive is already behind. The teams that navigate the process most effectively are usually the ones that built with ODD in mind from the beginning.
Institutional investors are evaluating more than the investment strategy. They are evaluating whether the firm is built to support institutional capital.
First, they want to see an operating model that can scale. Not just processes that work at launch, but infrastructure that will continue to work as AUM, investor expectations, and operational complexity increase.
Second, they want to see appropriate segregation of duties and internal controls. The same individual should not be responsible for valuing positions, approving trades, and reconciling cash. It sounds obvious, but it remains one of the most common weaknesses we see in early-stage firms.
Third, they look closely at the service provider ecosystem. Administrators, auditors, prime brokers, counsel, technology providers, and compliance partners all play a role in how investors assess operational maturity. The quality of that network is often one of the clearest indicators of how seriously a firm is being built.
Finally, they want to see a compliance program that is actively administered, not simply documented. Policies and procedures matter, but so does ongoing oversight. Personal trading reviews, marketing approvals, compliance testing, and periodic policy updates demonstrate that compliance is functioning as part of the business rather than existing as a binder on a shelf.
Launching is hard, and most of the work happens before the first trade. The teams that get it right treat the launch as the operational equivalent of building the firm twice, once for today, and once for the institutional firm they want to be in three years.
That is the work we do at Stable Rock. Our Launch Advisory & Start-Up Services practice supports managers from setup to scale, across entity strategy, vendor selection, accounting and CFO setup, and operational and compliance infrastructure buildout. If you are thinking through a launch, we are happy to help.
Six to twelve months from the decision to launch, depending on strategy, structure, initial seed capital, regulatory path, and how much of the work runs in parallel. Most first-time managers underestimate the time spent on entity formation, registration sequencing, and service provider negotiation. The honest answer is that the operational work takes as long as it takes, and trying to compress it tends to surface as gaps later.
Fixed operating costs for an emerging manager's management company are meaningful from Day One and scale with team size, geography, and complexity. The harder number is the working capital needed to bridge the gap between launch and the AUM that makes the management fee economics work. Most launches we work on build a realistic budget for both, with conservative AUM ramp assumptions, before the first allocation conversation.
You need the CFO function at launch. Whether that is a full-time hire, an outsourced relationship, or a hybrid arrangement depends on the size and complexity of the firm. For most emerging managers, an outsourced CFO and accounting setup is the right answer until the operating complexity requires a full-time CFO hire. In many cases, our team will support the full-time CFO with fractional controllers, operational, and regulatory and compliance practitioners.
Our senior led team has supported more than 1,000 entity launches across hedge funds, private equity firms, registered investment advisers, family offices, and the operating businesses around them. Whether you are three months from launch or still earlier in the process, we would welcome the conversation.
Schedule a conversation with our Launch Advisory & Start-Up Services team →
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