October 11, 2022

Submitted electronically via https://comments.cftc.gov
Mr. Christopher Kirkpatrick
Secretary of the Commission Commodity Futures Trading Commission Three Lafayette Center
1155 21st Street, NW Washington, DC 205281

Submitted electronically via [email protected]
Ms. Vanessa A. Countryman
Secretary Securities and Exchange Commission
100 F Street NE
Washington, DC 20549

Re: Request for Comment on Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers [RIN 3235-AN13; SEC Release No. IA-6083; SEC File No. S7-22-22]

Dear Mr. Kirkpatrick and Ms. Countryman:

The Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG”)1 welcomes the opportunity to comment on the joint Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC,” and, together with the SEC, the “Commissions”) proposal to amend Form PF (the “Proposal”).2 The Proposal sets forth proposed amendments to Form PF that would establish new reporting requirements, including the reporting of investment strategies, exposures, and master-feeder arrangements, among dozens of other new reporting requirements. The Commissions explain that the amendments “are designed to enhance the Financial Stability Oversight Council’s (“FSOC’s”) ability to monitor systemic risk.”3 As discussed below, the Proposal is one of two significant rule proposals relating to Form PF. The Proposal represents a paradigm shift to Form PF by, among other significant proposed changes, requiring fund-by-fund reporting (currently reporting using aggregated fund data is required), increasing the asset sub-classes that must be reported, and reintroducing reporting on all market factors. These sweeping changes should be thoughtfully considered in light of the existing oversight framework for private funds, the new burdens that the new Form PF reporting obligations would impose on investment advisers, the increased costs and barriers to entry for smaller and emerging funds and advisers, and the best, most practical and cost effective means to address the Commissions’ systemic risk goals.

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 Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers, 87 Fed. Reg. 53,832 (Sep. 1, 2022), https://www.govinfo.gov/content/pkg/FR-2022-09-01/pdf/2022-17724.pdf (hereinafter, the “Proposal”).