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MFA tells SEC comment period for Form PF proposal was far too short

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The Managed Funds Association (MFA), the trade association for the global alternative asset management industry, has submitted a comment letter to the US Securities and Exchange Commission (SEC) in response to its proposed amendments to Form PF, emphasising that the comment period was far too short to provide adequate comments to the SEC. 

The MFA intends to submit its full comments in the coming weeks.

“The SEC has proposed a substantial revision to Form PF, which will require entirely new, significant and costly technological builds for managers, service providers, and government agencies,” said MFA President and CEO Bryan Corbett. “Given the far-reaching consequences for the industry, including erecting higher barriers to entry, we don’t want to provide partial or incomplete comments. The comment periods provided this year have been consistently shorter than under any prior SEC, despite their agenda representing the most expansive series of rulemakings since the implementation of Dodd-Frank. The SEC claims they welcome comments from market participants for this and other rules but is unwilling to provide market participants adequate time to provide responses with the level of detail the Commission requests.”

In the letter, MFA points out that its request to the SEC and CFTC, co-signed by eight other associations, asking for a 60-day extension to the comment period was not granted. 

The MFA highlights that it did not want to provide incomplete comments given the potential impact of the proposal. 

The letter said: “This rule will have far-reaching consequences for our industry, and MFA does not want to provide partial or unexplained responses when with a few weeks more we can submit a much more useful response to the Commissions. As such, MFA is unable to submit comments by today’s deadline.

“The comment period was too brief for MFA and its members to appropriately analyse the changes to Form PF, understand their full scope and implications, and collect, analyse, and present the detailed information and comments that the Commissions need.”

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