Fund managers have been filing Form PF for almost a decade at this point, making them well-versed in the basic mechanics and issues associated therewith. The SEC’s proposed amendments to Form PF (Proposal) would cause the most material changes to the form since its introduction, however, which could force fund managers to revamp their operations and approach to completing the filing. In light of that, it can be helpful to look back at the procedural and operational difficulties fund managers faced when initially preparing Form PF a decade ago, as many of those shortcomings may become newly relevant as managers attempt to comply with changes to the form. In a guest article, Timothy Wilson, managing director, head of reporting and advisory services at Global Risk Management Advisors, and Jonathan B. Miller, senior counsel at Sidley Austin, outline material challenges, principle risks and key lessons gleaned from large fund advisers that filed Form PF anew in 2012. See our two-part series on the Proposal: “Require More PE Sponsors to File and One‑Business‑Day Reporting Criteria” (Feb. 22, 2022); and “Practical Impact on PE Sponsors and Reasons for Industry Backlash” (Mar. 1, 2022).