Private Fund Systemic Risk Reporting Regulation - Comment Letter - Alternative Investment Management Association - July 1, 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*


The Commodity Futures Trading Commission Registration and Systemic Risk Reporting
July 1, 2011 This letter was submitted in response to the announcement of a CFTC roundtable discussion on proposed changes to registration and compliance requirements for commodity pool operators (CPOs) and commodity trading advisors (CTAs). From the letter:

"AIMA's comments may be summarised as follows:

  • "There are significant cost implications stemming from registering with multiple regulators, and conforming to different national and international reporting regimes.
  • "We recommend that the Commission and the SEC coordinate their registration and reporting scope and approach, and seek to combine their systemic risk reporting requirements into a single form and/or undertaken to share information from one report.
  • "We would encourage the Commission to provide exemptions for small CPOs/CTAs, US advisers registered with the SEC, and non-US funds/advisers with a limited nexus to the US market (e.g., limited U.S. assets under management, clients or swap activity). This may most easily be achieved by providing exemptions similar to those proposed by the SEC, thereby exempting many smaller and non-US advisers.

"We suggest the simplification of reporting Form CPO-PQR, and the introduction of reporting thresholds and tiering, including an $1bn AUM threshold for systemic risk reporting on both Forms CPO-PQR (Schedule C) and CTA-PR (Schedule B), (consistent with the approach proposed with respect to Form PF."



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