Private Fund Systemic Risk Reporting Regulation - Comment Letter - Alternative Investment Management Association - April 12, 2011

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Dodd-Frank Timeline, Investment Adviser Reporting, Joint SEC-CFTC Rulemaking
Final Rule Issue Effective Date Compliance Date
November 16, 2011 March 31 2012 June 15, 2012*

Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF
April 12, 2011

In the comment letter, the association addresses the following categories:

  • hedge funds as a source of system risk;
  • the definition of “hedge fund;"
  • large private fund adviser thresholds and aggregation;
  • foreign private advisers and exempt reporting advisers;
  • the frequency of reports under Form PF;
  • the content of reports under Form PF;
  • the confidentiality of reports under Form PF;
  • international comparisons using the IOSCO template; and
  • the implementation of reporting obligations.


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