MFA and AIMA Submit Comments to SEC on Form PF Collection of Information Burdens

On March 12, MFA and AIMA filed a letter with the SEC on its request for comments on its collection of information on Form PF.  The reason for the SEC’s request was to renew its authorization with the Office of Management and Budget for the collection of information through Form PF.  The Associations supported the SEC’s role in overseeing systemic risk from the activities of investment advisers through private fund reports, but recommended that the Commission reduce the regulatory burden for filers.  In our letter, we recommended that the SEC reduce the frequency of the reporting and the number of month-end data points, and to simplify Form PF questions to better identify potential systemic risk, among other recommendations.

The Associations conducted a member survey and found that:

  • 46% of respondents spent between 250 and 650 hours/year for initial filings;
  • 54% of respondents spent between 650 and greater than 950 hours/year for initial filings;
  • 67% of respondents spent between 250 and 550 hours/year on subsequent filings; and
  • 33% of respondents spent between 550 and greater than 950 hours/year on subsequent filings.

The SEC estimated that it would cost $38,800 per large hedge fund adviser to file each subsequent Form PF report.  The Associations found that a quarterly filing for a large hedge fund adviser ranged from a conservative average of $46,000 to $59,000 (given the capped costs and number of hours spent on filings in the survey).

Click here to see a copy of the letter.