SIFMA AMG on SEC Form PF Proposal
Summary
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on the Commission’s proposed amendments to Form PF.
Excerpt
March 21, 2022
Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE Washington, DC 20549
Re: Amendments to Form PF to Require Current Reporting and Amend Reporting Requirements for Large Private Equity Advisers and Large Liquidity Fund Advisers File No. S7-01-22
Dear Ms. Countryman:
The Asset Management Group (the “AMG”) of the Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to provide comments to the United States Securities and Exchange Commission (the “Commission” or “SEC”) on the Commission’s proposed amendments to Form PF (the “Proposal”).2
The Proposal sets forth amendments to Form PF that would: (i) establish new current reporting requirements for large hedge fund advisers and advisers to private equity funds with respect to certain private funds they manage; (ii) decrease the threshold for inclusion as a “large private equity adviser;” (iii) require large private equity advisers to report new information about their activities and the investments of the funds they manage; and (iv) amend the information advisers to large liquidity funds are required to report to align with proposed amendments to information required of registered money market funds on Form N-MFP.3
This Proposal is 236 pages long, proposes a range of significant changes to complicated securities laws and complex financial markets, asks the public to respond to 120 questions, and provides only 51 days to respond during which we, and our members, are also working on responding to several additional new rulemakings from the Commission.4 In light of these facts, we and all other public commenters are limited in our ability to conduct a robust analysis of the Proposal and provide fulsome feedback to the
1 SIFMA AMG brings the asset management community together to provide views on policy matters and to create industry best practices. SIFMA AMG’s members represent U.S. and multinational asset management firms whose combined global assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds. For more information, visit http://www.sifma.org/amg.
2 Amendments to Form PF to Require Current Reporting and Amend Reporting Requirements for Large Private Equity Advisers and Large Liquidity Fund Advisers, Release No. IA-5950 (Jan. 26, 2022), available at https://www.sec.gov/rules/proposed/2022/ia-5950.pdf, hereinafter, Proposal.
3 Money Market Fund Reforms, Release No. IC-34441 (Dec. 15, 2021), available at https://www.sec.gov/rules/proposed/2021/ic-34441.pdf.
4 See U.S. Securities and Exchange Commission, Rulemaking Index, available at https://www.sec.gov/rules/rulemaking-index.shtml.