"CFTC and SEC Propose Reporting Rules for Private Fund Adviser Systemic Risk"

The CFTC and SEC recently issued proposed rules (the "Proposed Rules") under the Commodity Exchange Act and the Investment Advisers Act of 1940 to implement provisions of Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The Proposed Rules will require Private Fund Advisers registered with the SEC to report information to the SEC using a new reporting form, Form PF.  The Proposed Rules will also require registered CPOs and CTAs that advise one or more Private Funds and who are registered with the SEC as investment advisers to file Form PF with the SEC to satisfy certain CFTC filing requirements.

This Stroock Special Bulletin highlights the major provisions of the Proposed Rules.