April 12th, 2011
Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F St., NE
Washington, DC 20549
Mr. David A. Stawick
Secretary
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington DC 20581
RE: File # S7-05-11, Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF
Dear Ms. Murphy and Mr. Stawick:
Thank you for the opportunity to comment on the proposed rule, “Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF” (“Proposed Rule”), on behalf of Americans for Financial Reform.
AFR is a coalition of over 250 national, state, local groups who have come together to advocate for reform of the financial industry. Members of the AFR include consumer, civil rights, investor, retiree, community, labor, religious and business groups along with prominent economists and other experts.
This rule is an important step in implementing the transparency goals of the Dodd-Frank Act. According to Hedge Fund Research, hedge funds alone had almost $2 trillion in assets at the close of 2010, and showed record growth in assets under management. Leverage multiplied the actual assets controlled by hedge funds to a considerably greater figure. Private equity funds control approximately $1 trillion. Regulators will not have a full understanding of the financial sector and potential buildups of systemic risk so long as this sector remains in the shadows.
AFR shares the concerns expressed by the AFL-CIO regarding the importance of financial regulators obtaining comprehensive information on the activities of private funds. Gaps in the coverage of this sector could hamper efforts to fully measure financial interconnectedness and systemic risk. We therefore support the AFL-CIO’s letter commenting on this rule.
Thank you again for the opportunity to comment on this rule. If you have the further questions, please contact Marcus Stanley, Policy Director of Americans for Financial Reform at (202) 466-3672.
Sincerely,
Americans for Financial Reform