SEC Requests Comments on Form PF

Steven Lofchie Commentary by Steven Lofchie

The SEC is requesting comment on the collection of information on Form PF ("Reporting Form for Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors"). All private fund advisers with at least $150 million in private assets under management are required to complete Form PF. The form is intended to aid the Financial Stability Oversight Council in monitoring systemic risk, and in allocating its regulatory tools for nonbank financial companies.

The SEC is requesting comments on (i) the necessity of information collection, (ii) the accuracy of the SEC's reporting burden estimates, (iii) how to enhance the quality, utility and clarity of information requested, and (iv) how to minimize the burden of information collection.

Comments must be submitted by March 11, 2018.


Form PF is fundamentally useless. (See OFR Researchers Question the Utility of SEC Form PF as a Risk Management Tool.) The financial industry spent hundreds of millions of dollars developing systems to answer questions that were poorly considered and written. Anyone familiar with the relevant area of law could see that the questions posed on the form could not possibly generate useful or consistent results. Leaving aside the time and money wasted, if one believes that the information properly collected might have been useful to the regulators, then the waste was even greater, because an opportunity to acquire useful information was squandered. The real question for regulators now is how can they improve their procedures so as not to make a similar mistake or squander additional resources.

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