Private Fund Systemic Risk Reporting Regulation - Comment Letter - Investment Adviser 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

According to the comment letter, the SEC should:

  • "modify the treatment of 'parallel managed accounts;'
  • narrow the definition of 'hedge fund;'
  • eliminate aggregation requirements for certain related persons for reporting threshold purposes;
  • exempt smaller private fund advisers;
  • permit flexibility in reporting data and methodologies;
  • require certain data proposed to be reported in Form ADV, Part 1 to be reported in Form PF instead;
  • reconsider the timeframes and frequency of filing Form PF; and
  • confirm treatment of non-U.S. funds under Form PF, among other changes."


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