To further achieve the Commissions objectives, it is respectfully suggested and requested that private investments in other private funds continue to be excluded from the thresholds for quarterly PF filing. Reviewing the Commissions current proposal, the language change to #7 requiring inclusion of private fund investments in other private funds for determining the thresholds for quarterly filing as a large hedge fund advisor, contrary to the stated intent of the proposed rule change, actually increases the regulatory reporting burden for certain advisors potentially causing fund of fund advisors that currently file annually under the in-effect Form PF instructions to be required to comply with a quarterly PF filing requirement schedule; a significant burden that increases costs and is contrary to the Commission's objectives. Given the Commissions intent to reduce unnecessary and ineffective reporting requirements, the general lack of look through information, the potential for double-counting of assets, and overlapping reporting requirements (underlying private funds may very well also be reporting), a change to the proposed rule is requested. A proposed language is provided below Proposed language - edit (add: can exclude; delete: must include) 7. I advise a private fund that invests in other private funds (e.g., a “fund of funds”) or trading vehicles. How should I treat these investments for purposes of Form PF? Reporting thresholds. You can exclude the value of private fund investments in other private funds in determining whether you are required to file Form PF and whether you meet thresholds for filing as a large hedge fund adviser, large liquidity fund adviser, or large private equity fund adviser and whether a reporting fund is a qualifying hedge fund.