Promote a Sensible Approach to Asset Management Regulation and Reporting

Hedge fund managers are subject to robust regulations designed to oversee activities of the funds that they manage. MFA supported systemic risk reporting and we believe that systemic risk regulation should be activities-based, and data collection should be rationalized across activities and not focused on any single metric.

Alternative investment fund managers report vast amounts of sensitive data to regulators through registrations, regulatory reporting requirements, and recordkeeping requirements. Many managers are required to be registered as investment advisers with the SEC, as well as commodity pool operators and commodity trading advisors with the CFTC; and consequentially, are required to routinely file multiple forms with the SEC, CFTC, and NFA. The regulatory and systemic risk filing requirements are similar, but different enough to require separate compliance and filing systems. To promote good government, assist regulators with prioritizing limited resources and to enhance the efficient functioning of capital markets, policymakers should encourage the SEC and CFTC to work together to minimize duplicative regulatory requirements, harmonize data collection, and eliminate data requests that do not further regulators’ objective of monitoring systemic risk.