Proposed changes to current Form PF requirements are "a fundamental rewrite of the form that undermines regulators’ ability to accurately identify and assess systemic risk", according to the Managed Funds Association, the trade association for the global alternative asset management industry.

Proposed changes to current Form PF requirements are "a fundamental rewrite of the form that undermines regulators’ ability to accurately identify and assess systemic risk", according to the Managed Funds Association (MFA), the trade association for the global alternative asset management industry.

The MFA has submitted a comprehensive comment letter to the US Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) in response to their proposed amendments highlighting that changes would also impose significant burdens on advisers and commodity pool operators.
  
The comment letter supplements MFA’s October letter that emphasised the comment period was too short for MFA to provide an adequate response before the SEC and CFTC's deadline. It emphasises that the proposed amendments to Form PF will capture routine market events that do not help regulators assess systemic risk. 

The MFA also believes that consistent with other SEC rulemaking, the Commission underestimates the cost of compliance with the proposed rules.