SEC Investment Management Attorneys Offer a Roadmap to SEC Rulemaking and Public Comments

Under Chair Gary Gensler, the SEC has pursued an aggressive rulemaking agenda that has touched many aspects of the financial services industry and posed significant new challenges for private fund advisers. A recent Alternative Investment Management Association (AIMA) program offered a roadmap to the SEC rulemaking process, focusing on the importance of the public comment period; ways advisers can tailor effective comments, whether individually or through industry associations; and the opportunity to provide input to the SEC even after the comment period ends. The program was led by Suzan Rose, senior advisor to AIMA, and featured Robert Holowka and Nathan Schuur, both Senior Counsel in the SEC Division of Investment Management, as well as Michael A. Kitson, deputy CCO and counsel at Bridgewater Associates LP. This article synthesizes the key lessons from the program. See “How the Financial Climate and SEC Rulemaking Is Affecting the PE Industry and GP‑LP Negotiating Dynamics” (Jun. 7, 2022); and our coverage of recent SEC rulemaking on climate risk disclosure; cyber risk management; environmental, social and governance disclosure; Form PF; and private funds.

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