MFA Files Letter with SEC on Rationalizing Form PF

Today, MFA filed a letter with Chairman Clayton requesting that the SEC streamline Form PF to reduce burdens both on regulators and market participants. These revisions are in line with the 2017 Treasury Report on Asset Management’s recommendation that  “the SEC, the CFTC, SROs, and other regulators should work together to rationalize and harmonize the reporting regimes” in addition to CFTC Chairman Giancarlo’s Project KISS Initiative.

In that spirit, the letter recommends that the SEC, CFTC and FSOC work together to revise Form PF to:

  • Reduce the reporting frequency and number of monthly data points;
  • Incorporate alphanumeric identifiers to mitigate potential cyber breaches;
  • Revise certain questions to better identify potential systemic risk;
  • Simplify or eliminate certain questions that are duplicative or overly complex; and
  • Harmonize reporting with CFTC as originally intended.

MFA submitted a marked-up version of Form PF with detailed comments and recommendations for the Commission’s review to improve the accuracy and relevancy of the information that the SEC and FSOC reviews about the industry and individual managers and funds.