On June 28, 2012 and July 19, 2012, the staff of the Securities and Exchange Commission (Staff) provided additional guidance on Form PF by updating its frequently asked questions on Form PF (FAQs).  The Staff has offered reporting entities some flexibility in how they respond to certain questions in Form PF, provided that such reporting is consistent with internal reporting and reporting to investors and provided further that reporting methodologies are explained in Question 4 of Form PF.  Among other things, the additional guidance: defines key terms in Form PF; clarifies the reporting obligations for specific questions; provides instructions for performing certain calculations necessary for reporting information on Form PF; and provides guidance on transitional mechanics for preparing and filing Form PF.  See also “How Should Hedge Fund Managers Allocate Form PF Expenses Between Their Hedge Funds and Their Management Entities?,” Hedge Fund Law Report, Vol. 5, No. 25 (Jun. 21, 2012).