January 27, 2022
AUM size for reporting threshold should not be the only metric used to consider a firm a large private equity adviser. Adviser strategies with listed equity, long bias, no use of leverage/borrowing, currently have the majority of Form PF filled out with zeros and N/A. If the threshold is lowered you will now have these advisers filing quarterly with information that really doesn't change and won't provide any better assessment of systemic risk of these firms, in my opinion. The current online form is burdensome as is because it requires all fields to be filled in with something even if not applicable. I feel you will have to provide a much better user experience when filing if you now deem more firms large advisers who will then have to file quarterly. Regardless of your decision, the online Form PF needs an overhaul.