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

The Securities and Exchange Commission (the "SEC") and the Commodity Futures Trading Commission (the "CFTC") recently issued Final Rules under the Commodity Exchange Act and the Advisers Act to implement provisions of Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").  The Final Rules will require Private Fund Advisers registered with the SEC to report information to the SEC using a new reporting form, Form PF.  The Final Rules will also require registered commodity pool operators and commodity trading advisers that advise one or more private funds and who are registered with the SEC as investment advisers to file Form PF with the SEC, which would also satisfy certain CFTC filing requirements that the CFTC is currently considering.

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