The SEC has designated FINRA to develop and maintain the filing system for proposed Form PF, which would contain information about funds managed by exempt reporting advisers.  Back in January, the SEC proposed Rule 204(b)-1 which would require exempt reporting advisers (i.e. fund advisers with less than $150 Million in AUM) to periodically prepare and file Form PF.  The SEC is now indicating that firms will use an electronic system operated by FINRA to file the form along with the required ADV.  The SEC will make the information reported to the Financial Stability Oversight Council to monitor systemic risk. 

 

OUR TAKE: SEC has been leveraging FINRA's systems for years (e.g. Form ADV filings, licensing).  One of FINRA's arguments that it should regulate advisers is that it already has all the relevant information.