Private Fund Systemic Risk Reporting Regulation - Comment Letter - Invesco - April 24, 2012

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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
April 24, 2012

In their comment letter, Invesco addresses the following concerns:

  • CFTC rule requirements that are not addressed in the Proposal;
  • The cost-benefit analysis and estimate of time spent;
  • Lack of a gap analysis to identify material CFTC disclosure elements missing in the current SEC disclosure regime;
  • Prior performance disclosure requirement is inconsistent with SEC regulation;
  • Break-even calculations and tables;
  • Placement of CFTC disclosure elements in the SEC prospectus document; and
  • Coordinating dual regulator disclosure review.


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