Subject: File No. S7-03-13
From: Bruce Runciman
Affiliation: Axiom SL

August 28, 2013

To:  Rule-comments@sec.gov
Ref: File Number S7-03-13
Proposed Amendments to Form PF Section 3 - Liquidity Private Funds
Re-numbering and Re-sequencing of questions within Form PF requires that the respondents update their electronic versions of the forms, XML Schema and internal system data cross-references.  This is not an inconsequential effort for the Investment Advisors responding to this reporting requirement.
Suggestion:
 Retain the existing numbering ranges for questions in Sections 3 and 4 of Form PF.
This can be accomplished by merging two related questions in Section 3 thereby completing this section with Question # 64, and keeping Section 4 question numbers intact.  The best suited questions to merge are Q52 & Q53 or Q53 & Q54 resulting in a merged question with parts (a) & (b) to complete the sequence of questions in their existing order.

 

Bruce Runciman
Senior Vice President

Axiom SL