Private Fund Systemic Risk Reporting Regulation - Comment Letter - Investment Adviser Association - April 12, 2011
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|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."