February 25, 2022
Enhancing systemic risk monitoring is welcome. Trigger events for large hedge fund advisers (e.g. extraordinary losses, margin calls...) should be based on the latest net asset values so that reporting is dynamic. Using net asset values as reported in the latest regulatory filings (end of prior quarter or fiscal year) will result in over or under reporting, as highlighted by the Commission and potentially result in an inefficient use of Commission resources. Most hedge funds do calculate monthly or even weekly net asset values.