February 21, 2022
I support this proposal and the inclusion of sections 5 and 6 in future Form PF filings. The addition of requirements to submit timely reports from funds under financial stress will provide valuable data on the state of the market allowing regulators and the market itself to better respond to developing risks.
Regarding the proposed lower limit of 1.5bn AUM to require more detailed reporting as a large fund, I believe lowering the limit further to 1bn or slightly less would be preferable given the frequent and significant leverage used by many funds which can aggregate to larger systemic risk. At 1bn AUM these funds will already have dedicated employees to handle the additional paperwork proposed here. As noted in this proposal there has been a significant growth in private equity funds over the past decade and lowering the threshold for reporting may be prudent in avoiding a risk-assessment blindspot caused by multiple smaller-to-mid-size funds coming under duress at the same time.
The one business day turnaround for paperwork filing seems appropriate in this case due to the increasing speed at which markets can move.