Although apparently driven by concerns relating to pension fund investors, Chair Gensler did not provide any details regarding the potential reforms under consideration. The SEC has brought a number of enforcement actions against fund managers in prior years alleging failure to disclose various conflicts of interest and inadequate fee/expense disclosure under general fiduciary principals. The SEC may now be considering more proscriptive disclosure requirements.

In House testimony given earlier this year, Gensler noted the significant growth in private funds and private fund assets over the past five years.  Given these changes, he had requested staff recommendations regarding potential enhanced reporting and disclosure through Form ADV, Form PF, or other possible reforms.

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