September 14, 2022

Ms. Vanessa A. Countryman Secretary
U.S. Securities and Exchange Commission
100 F. Street NE
Washington, DC 20549-1090

Mr. Christopher Kirkpatrick
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581

Submitted via email to [email protected]
Submitted via CFTC Comments Portal at http://comments.cftc.gov

Re: File No. S7-22-22

Dear Ms. Countryman and Mr. Kirkpatrick:

The undersigned trade associations (the “Associations”) respectfully request a 60-day extension of the comment period for the Form PF Proposed Rules with a new deadline of December 12, 2022. On August 10, 2022, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) (together, the “Commissions”) released a 298-page Proposed Rule, “Amendments to Form PF to Amend Reporting Requirements for All Filers and Large Hedge Fund Advisers” (the “Form PF Proposed Rules”). The Form PF Proposed Rules were subsequently published in the Federal Register on September 1, 2022. The Form PF Proposed Rules propose complex and sweeping changes to the Form PF that amount to a substantial rewrite of the current form. The Form PF Proposed Rules require significant technical expertise to assess the new requests, the physical and practical challenges in gathering and/or calculating the information requested on a routine basis, and responding to the Commissions’ questions and developing recommendations to best achieve the objective of regulators. Given the extensive and technical rewrite of Form PF, registrants and commenters will need to synergize among key firm executives and departments including the Chief Operating Officer, Chief Legal Officer, Chief Financial Officer, Chief Technology Officer, Chief Compliance Officer, and others to assess how to gather and calculate the information required by the sweeping changes to Form PF.

The Commissions request comment on over 200 questions covering a wide range of topics, including amended reporting for all filing advisers and private funds, amended reporting by large hedge fund advisers and qualifying hedge funds, and amended reporting by hedge funds. Despite the breadth of the request for comments in the Form PF Proposed Rules, the Commissions have set a deadline for comments of October 11, 2022. The current deadline is simply too short for the Associations and their members to appropriately analyze the changes to Form PF, understand their full scope and implications, and collect, analyze, and present the detailed information and comments that the Commissions seek from stakeholders and the public.

Finally, we note that earlier this year the SEC proposed “Amendments to Form PF To Require Current Reporting and Amend Reporting Requirements for Large Private Equity Advisers and Large Liquidity Fund Advisers” (“January Form PF Proposal”), proposing to add a significant new reporting section to Form PF and make substantial changes to existing sections.2 The January Form PF Proposal has significant implications for registrants by expanding who must report, what must be reported, and when reports must be made. Both the Form PF Proposed Rules and January Form PF Proposal are linked in requiring significant changes to how registrants must analyze and gather relevant data for Form PF reporting.