April 19, 2022
I attended a webinar that Ms. Schleppegrell spoke and she said to submit comments on this proposal. We are a small private fund advisor. We have 4 employees. We manage one fund. We are SEC registered. We currently comply one way or another with most of your proposal and I encourage you to ask current private fund advisors in what manner they do comply already and possibly use that as your grandfather method. My fear is you will make us re-create the wheel when it comes to reporting when our fund admin already takes care of most of the elements you describe. Our admin already sends monthly statements directly to the investor with capital changes, performance, and fee class. We already have an annual audit of fund financials and its sent to all investors. Our only expenses to the fund is the management fee and custody fee. Both those fees are stated on the audited financials that is distributed to investors. We are not equipped to take reporting in house from our admin to create quarterly packages under the format you describe. I'm not sure to what extent our admin is willing to change their reporting to meet these requirements and at what charge to us. My point is the information is there and being given to our investors, just not in the quarterly format you propose. I think advisors who have already been disclosing/reporting these things in their own way for years should not have to change.