MFA is strongly supportive of the principles underlying the design of FRAME, namely simplicity, proportionality and international alignment. In the context of international alignment of private fund reporting regimes, we welcome the FCA’s efforts to align certain concepts and requirements with the U.S. Securities and Exchange Commission’s (“SEC”) Form PF framework.
MFA explains:
- Greater consistency across jurisdictions can significantly reduce operational complexity, compliance costs, and duplicative reporting obligations for globally active managers, while improving the comparability and usefulness of regulatory data.
- Many UK managers also file Form PF, so we encourage the FCA, where appropriate, to align its reporting requirements, definitions, and calculation methodologies with Form PF so firms can leverage existing reporting controls, systems, and governance processes.
- Given the granularity of Enhanced Reporting, we would ask the FCA to consider raising the threshold for its application to £750 million NAV to further align with the thresholds in the new AIFM classification system.
