September 20, 2022
Following what appeared to be a positive response from the SEC to advocacy by the IAA and others on its unreasonably short comment deadlines, the SEC has gone back to publishing significant proposals with deadlines of 60 days following issuance of the proposal.
The IAA continues to push back, calling for more time to allow stakeholders to weigh in on proposals that will likely have sweeping effects on advisers, investors, and the financial markets. To that end, we recently joined a letter urging the SEC and CFTC to extend the comment period for their joint Form PF proposal published on August 10. The new proposal includes a significant rewrite of the entire form and, as reported in IAA Today, comes on the heels of an earlier set of Form PF amendments proposed in January for private equity, hedge fund, and liquidity fund advisers, on which we provided extensive comments.
The joint letter urges the regulators to extend the comment period by 60 days, from October 11 to December 12, 2022. The original deadline is insufficient to allow commenters the necessary time to analyze the complex and highly technical proposal, understand its full scope and implications, collect responses to the questions raised therein, and address its interplay with the earlier PF proposal. We continue to believe that a more reasonable comment period will provide the Commissions with more meaningful stakeholder input that will better help them achieve their policy goals in a less burdensome manner.
We are working with members to analyze the new Form PF proposal, including the potential interrelated impacts of the SEC’s earlier Form PF proposal, and to develop our response. If you have questions or comments on the proposal or would like to join our Form PF Working Group, please contact Monique Botkin, IAA Associate General Counsel, at monique.botkin@investmentadviser.org.
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