AIMA, the world’s largest alternative investment trade body, has today submitted its response to the SEC and CFTC's proposed amendments to Form PF.

AIMA welcomes the proposal as a strong step toward the right balance between collecting the data regulators need to monitor systemic risk and avoiding excessive or overly burdensome reporting — in particular the higher filing and reporting thresholds, which would relieve many smaller managers that pose no systemic risk, and the removal of several of the most burdensome questions introduced in February 2024.

The response also sets out a number of practical steps to make Form PF more useful for regulators and less onerous for the industry. These include aligning Form PF with existing US GAAP and other SEC, CFTC, FINRA and Federal Reserve reporting conventions to improve data quality and reduce duplication; removing low-value, duplicative and stale monthly data points; providing realistic transition timelines once final technical specifications are available; and taking a measured, proportionate approach to any new reporting requirements for hedge funds and private credit funds.

Much of the response mirrors the philosophy of AIMA's white paper on systemic risk reporting and it's more than decade-long experience of gathering of data on the private credit market.  

Commenting on the submission, Jack Inglis, CEO of AIMA, the world’s largest alternative investment trade body,  said: "We are very grateful to the SEC and CFTC for reopening this file and for their willingness to review Form PF against its core purpose of monitoring systemic risk. The proposal is a welcome step in the right direction, and our response — which builds on the philosophy of our white paper on systemic risk reporting — offers constructive, practical suggestions to make the data more useful for the regulators themselves while reducing unnecessary cost and complexity for the firms that file it. We hope these will be given careful consideration, and we stand ready to keep working with the Commissions and their staff to deliver a framework that serves both the regulatory objective and the industry well."