CFTC and SEC Proposed Rules on Reporting by Investment Advisers

On January 26, the CFTC and the SEC proposed new rules to implement provisions of the Dodd-Frank Act to assist the Financial Stability Oversight Council in its assessment of systemic risk. The proposed SEC rule would require SEC-registered investment advisers that advise private funds to file Form PF with the SEC. The proposed CFTC rule would require commodity pool operators and CFTC-registered commodity trading advisors who are also SEC-registered investment advisers that advise one or more private funds to satisfy certain proposed CFTC filing requirements by filing Form PF with the SEC. Comments on the proposed rules must be submitted within 60 days after publication in the Federal register. SEC Rule.