Changes would make data more comparable and useful to regulators and reduce burdens on managers
Washington, D.C. — MFA made recommendations to the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) on how to streamline Form PF in a letter submitted yesterday.
“The problem with Form PF isn’t that regulators receive too little data. It’s that they receive a flood of poorly organized data,” said Bryan Corbett, MFA President and CEO. “Fund managers spend significant time and resources producing reports that are disconnected from how they actually manage risk. This makes the information difficult to compare across firms and often obscures, rather than clarifies, economic exposures.”
Form PF has nearly doubled in size since its original adoption. Changes under the previous administration have significantly increased reporting burdens on fund managers and their investors while producing data that is often difficult to compare across firms and less useful for systemic risk monitoring. MFA’s recommendations would streamline the form, improve data quality, and ensure regulators receive information that better reflects how investment advisers actually operate and manage risk.
MFA’s key recommendations include:
- Focus reporting where it provides the most value. Raising reporting thresholds would allow regulators to concentrate resources on funds and information most useful to systemic risk monitoring. This would reduce unnecessary reporting from smaller funds without reducing regulators visibility into broader market trends.
- Report exposures at the portfolio level. Advisers manage risk across entire portfolios, but current reporting requirements often require the same portfolio to be broken apart across multiple legal entities. Allowing more consolidated reporting would provide regulators with a clearer picture of actual economic exposures.
- Improve consistency and comparability across filings. Aligning Form PF with existing accounting standards and regulatory reporting frameworks would reduce the need for bespoke calculations and provide regulators with more standardized, comparable, and decision-useful information.
- Streamline event reporting requirements. Providing more practical reporting timelines and clearer reporting triggers would improve the accuracy of information submitted to regulators while reducing unnecessary filings.
Read the full letter here.
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About the global alternative asset management industry
The global alternative asset management industry — including hedge funds, private credit funds, and hybrid funds — serves thousands of public and private pension funds, charitable endowments, foundations, and other global institutional investors. The industry provides portfolio diversification and risk-adjusted returns to help meet their funding obligations and return targets throughout the economic cycle.
About MFA
Managed Funds Association (MFA), based in Washington, D.C., New York City, Brussels, and London, represents the global alternative asset management industry. MFA’s mission is to advance the ability of alternative asset managers to raise capital, invest it, and generate returns for their beneficiaries. MFA advocates on behalf of its membership and convenes stakeholders to address global regulatory, operational, and business issues. MFA has more than 180 fund manager members, including traditional hedge funds, private credit funds, and hybrid funds, that employ a diverse set of investment strategies. Member firms help pension plans, university endowments, charitable foundations, and other institutional investors diversify their investments, manage risk, and generate attractive returns throughout the economic cycle.