Key Takeaways
- • The Managed Funds Association (MFA) submitted recommendations to the SEC and CFTC to streamline Form PF, arguing that regulators receive "a flood of poorly organized data" rather than insufficient information, according to MFA President and CEO Bryan Corbett.
- • Form PF has nearly doubled in size since its original adoption, with recent changes significantly increasing reporting burdens on fund managers while producing data that is difficult to compare across firms and less useful for systemic risk monitoring.
- • MFA recommends raising reporting thresholds to concentrate regulatory resources on funds and information most relevant to systemic risk, allowing smaller funds to reduce unnecessary reporting without reducing regulators' visibility into broader market trends.
- • The association proposes allowing consolidated portfolio-level reporting rather than requiring the same portfolio to be broken apart across multiple legal entities, which would provide regulators with a clearer picture of actual economic exposures and how advisers actually manage risk.
Summary
The Managed Funds Association has formally recommended structural reforms to Form PF, the primary regulatory reporting mechanism for systemic risk monitoring overseen jointly by the Securities and Exchange Commission and Commodity Futures Trading Commission. In a letter submitted to both agencies, MFA leadership articulated a fundamental critique of the current framework: the problem is not insufficient data but rather the quality and organization of the information being reported.
MFA President and CEO Bryan Corbett stated that fund managers expend significant time and resources producing reports that are disconnected from actual risk management practices, creating a data environment that obscures rather than clarifies economic exposures across the industry. Since Form PF's original adoption, the reporting requirement has expanded substantially—nearly doubling in size—with recent regulatory changes intensifying compliance burdens on both fund managers and their investors.
The association's recommendations focus on two primary reforms. First, MFA proposes raising reporting thresholds to allow regulators to concentrate oversight resources on funds and datasets that provide the greatest value for systemic risk assessment. This approach would reduce reporting requirements for smaller funds without diminishing regulatory visibility into broader market trends. Second, MFA advocates for portfolio-level consolidated reporting, arguing that current requirements fragment a single portfolio across multiple legal entities, preventing regulators from obtaining a transparent view of actual economic exposures. By aligning reporting structures with how investment advisers genuinely operate and manage risk, these changes would improve data comparability across firms and enhance the utility of Form PF data for regulatory purposes.
MFA President and CEO Bryan Corbett stated that fund managers expend significant time and resources producing reports that are disconnected from actual risk management practices, creating a data environment that obscures rather than clarifies economic exposures across the industry. Since Form PF's original adoption, the reporting requirement has expanded substantially—nearly doubling in size—with recent regulatory changes intensifying compliance burdens on both fund managers and their investors.
The association's recommendations focus on two primary reforms. First, MFA proposes raising reporting thresholds to allow regulators to concentrate oversight resources on funds and datasets that provide the greatest value for systemic risk assessment. This approach would reduce reporting requirements for smaller funds without diminishing regulatory visibility into broader market trends. Second, MFA advocates for portfolio-level consolidated reporting, arguing that current requirements fragment a single portfolio across multiple legal entities, preventing regulators from obtaining a transparent view of actual economic exposures. By aligning reporting structures with how investment advisers genuinely operate and manage risk, these changes would improve data comparability across firms and enhance the utility of Form PF data for regulatory purposes.
Go deeper than the headline
Research every firm in this story, track the ones that matter and get the daily briefing — free for 7 days.