ARTICLE
26 September 2018

MFA Advises SEC To Reduce Regulatory Burden Of Form PF

CW
Cadwalader, Wickersham & Taft LLP

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The Managed Funds Association urged the SEC to simplify the systemic risk reporting process for advisers of privately offered investment funds.
United States Finance and Banking

The Managed Funds Association ("MFA") urged the SEC to simplify the systemic risk reporting process for advisers of privately offered investment funds. Investment advisers with greater than $150 million in private fund assets under management are required to provide significant financial information in Form PF. In a letter to the SEC, the MFA recommended that the SEC, the CFTC and the Financial Stability Oversight Committee amend the reporting process by:

  • reducing the reporting frequency and number of monthly data points;
  • incorporating alphanumeric identifiers to alleviate potential cyber breaches;
  • revising questions to better identify potential systemic risk;
  • simplifying or jettisoning duplicative or overly complex questions; and
  • harmonizing reporting with the CFTC.

Commentary / Steven Lofchie

Form PF is absolutely useless. See, e.g., OFR Researchers Question the Utility of SEC Form PF as a Risk Management Tool. In its current state, the form is a waste of time and money for both the industry and the regulators who must review the "data" it provides. Any person knowledgeable in the area, looking at the questions asked, would realize that the questions are completely ambiguous, and that the information they elicit are of little value.

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