Subject: Amendments to Form PF to Amend Reporting Requirements for All Filers and Large Hedge Fund Advisers (File No: S7-22-22/RIN 3038-AF31)
From: Robert Rutkowski
Affiliation:

Oct. 13, 2022


Gary Gensler, Chair
SEC Headquarters
100 F Street, NE
Washington, DC 20549


Vanessa A. Countryman
Secretary, Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090


Chairman Rostin Behnam
Commissioner Dawn DeBerry Stump
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581


Re: Amendments to Form PF to Amend Reporting Requirements for All Filers
and Large Hedge  Fund Advisers (File No: S7-22-22/RIN 3038-AF31)

Dear Chairs:

AFREF sent a letter in support of proposals from both the Securities and
Exchange Commission and Commodity Futures Trading Commission that would
provide the agencies and by extension the Financial Stability Oversight
Council with additional information from the $18 trillion private fund
industry related to: more specific details about their holdings in
digital assets, more granular data around derivatives and swaps that
reference corporate debt and information about the base currencies their
holdings are denominated in. Such information will help regulators
ensure that they have a clearer picture into the holdings and risks
posed by the $18 trillion private fund industry in order to be able to
react proactively to any risks that may threaten the financial system.

Full letter:
https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-d56c32865d30ee88&q=1&e=c3f592c2-7583-42f5-8e6a-a1c8aa4b5429&u=https%3A%2F%2Fourfinancialsecurity.org%2F10-11-22-non-bank-afref-comment-to-sec-and-cftc-on-form-pf-final%2F

Take the time to review these recommendations and give them the weight
they deserve.

Yours sincerely.
Robert E. Rutkowski

cc:
Legislative Correspondence Team
1705 Longworth House Office Building
Washington DC 20515


2527 Faxon Court
Topeka, Kansas 66605-2086