The U.S. Chamber of Commerce’s Center for Capital Markets Competitiveness (“Chamber”) appreciates the opportunity to comment on the rules proposed collectively by the Commodity Futures Trading Commission (“CFTC”) and Securities and Exchange Commission (“SEC”) (together “the Commissions”) that would amend private fund reporting rules under Form PF (“Proposal”).

Form PF is a confidential reporting form that requires certain SEC-registered investment advisers to private funds, including those also registered with the CFTC as Commodity Pool Operator (CPO) or Commodity Trading Adviser (CTA), to report upon the occurrence of key events. Form PF was adopted in 2011 to comply with the Dodd-Frank Act of 2010.The 2011 adopting release states the goal that “these reporting forms will provide FSOC and the Commissions with important information about the basic operations and strategies of private funds and help establish a baseline picture of potential systemic risk in the private fund industry.”

The private funds marketplace is critical to capital formation globally and in the United States. It has evolved over time into a highly efficient and well-developed market characterized by a high degree of competitiveness and sophistication among market participants. This Proposal would unnecessarily disrupt the private funds marketplace, imposing substantial costs on fund managers and investors alike, while imparting little, if any, benefit to enhancing systemic risk monitoring – the primary objective stated by the Commissions.