The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) on a proposal, Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF, File No S7- 05-11, Release No. IA-3145.  Under the terms of the proposal, investment advisers registered under the Investment Advisers Act of 1940, which serve as investment advisers to private funds and certain commodity pool operators and commodity trading advisers would be required to report information necessary for the SEC and other regulators, including the Financial Stability Oversight Council (the FSOC), to assess systemic risk.  SIFMA AMG offers observations and recommendations regarding the proposal, including: 1) the determination of systemic risk; 2) alternatives to implementation beginning January 15, 2012; and 3) certain private funds and hedge funds should be exempted from reporting obligations under Form PF.