On March 22, 2012, the Technical Committee of the International Organization of Securities Commissions (IOSCO) published an updated list of categories of data to be used in connection with annual surveys of hedge fund managers by IOSCO’s Task Force on Unregulated Financial Entities. IOSCO conducted its first hedge fund survey in September 2010, soliciting information in categories publicly identified in February 2010. See “Does the IOSCO Hedge Fund Disclosure Template Foreshadow the Content of Hedge Fund and Hedge Fund Adviser Disclosures to be Required by the SEC?
,” Hedge Fund Law Report, Vol. 3, No. 15 (Apr. 16, 2010). IOSCO intends to conduct its second hedge fund survey in September 2012, and to conduct such surveys annually thereafter, each September. The September 2012 hedge fund survey will solicit information from hedge fund managers in at least the updated data categories. According to a press release, those categories incorporate “lessons learned [since February 2010] and recent legislative developments in the U.S. and Europe.” The stated purpose of the annual surveys is to “enable the collection of internationally consistent data which can be shared to facilitate international supervisory cooperation.” This article describes the ten categories of information in which IOSCO will solicit information, discusses the context and limits of the annual surveys and highlights questions raised by IOSCO’s announcement to conduct annual surveys.