Second Form PF Proposal: Rationale, Commissioner Views and Need for Comments (Part Two of Two)

In the decade since Form PF was adopted, the private funds industry has grown exponentially, and the types of investments and strategies used by hedge and private equity funds have expanded and grown more complex. Thus, Form PF was ripe for an update. As a result, the SEC’s release of proposed amendments to Form PF in January 2022 was no surprise to industry stakeholders. What was a surprise, however, was the SEC’s second set of proposed amendments (Proposal) to Form PF released several weeks ago in conjunction with the CFTC. This second article in our two-part series discusses the rationale for the Proposal; the views of Commissioners from the SEC and CFTC on the Proposal; and the reasons thoughtful comments to the Proposal are so important. The first article provided an overview of the Proposal and its five goals. For additional commentary from Lombardo, see our two-part series: “SEC’s Proposed Amendments to Form PF and Advisers Act Introduce Uncertainty, Increase Burden on Compliance Staff” (Apr. 21, 2022); and “Quarterly Reporting Requirements and Prescriptive Prohibited Activities in the SEC’s Proposed Amendments to the Advisers Act” (Apr. 28, 2022).

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