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Second Form PF Proposal: Rationale, Commissioner Views, and Need for Comments (Part Two of Two), Hedge Fund Law Report

September 22, 2022

Hedge Fund Law Report released the second article in a two-part series analyzing the US Securities and Exchange Commission’s (SEC’s) second set of proposed amendments to Form PF—in conjunction with the US Commodity Futures Trading Commission (CFTC)—released on August 10, 2022. Partner Christine Lombardo addresses the rationale behind the proposal, the views of commissioners from the SEC and CFTC on the proposal, and why thoughtful comments to the proposal are so important.

“It’s interesting to me that the SEC would put out two proposals on the same rule within the same year,” said Christine.

"I don’t think we anticipated another proposal. Actually, when I saw [Form PF] on the SEC’s agenda, I thought maybe it was reproposing and changing aspects of the original proposal, but obviously, that wasn’t the case.”

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