News & Events

Corporate Partner David Blass was quoted extensively in an article published by Private Equity Law Report titled, “Practical Impact on PE Sponsors of the Proposed Amendments to Form PF and Reasons for Industry Backlash (Part Two of Two).” The article examined the SEC’s recently proposed amendments to Form PF and the impact these could have on fund managers. David noted how the proposal contains inconsistencies between the scope and purpose of the Form PF disclosures, with particular reference to the reporting events required of PE advisers given that the FSOC is the intended recipient of the filing information. “It is hard to imagine what the FSOC would do with the information that a PE fund terminated at the end of its term,” he explained. He further noted that the SEC needs to connect the new reporting requirements to true systemic risk or otherwise consider abandoning those parts of the proposal. David also commented on the difficulty of the one-business-day reporting requirement, stating that “the many other burdens a fund manager would likely be facing surrounding some of the events requiring that reporting,” including ensuring a proper internal review of the information contained in the filing, should also be considered.

To read the full article, please click here (subscription required).