Key takeaways:

• This memo serves as a reminder that private equity funds (and their managers/advisers) are subject to various types of regulation under U.S. federal law and non-U.S. law.
• All registered investment advisers who advise private equity funds will be required to file an annual update to Form PF, the systemic risk reporting form, within 120 days after the end of the fiscal year.
• Managers or general partners of private funds that trade “commodity interests” and rely on an exemption from registration with the U.S. CFTC must reaffirm such exemption within 60 days following December 31.‬
• Marketing a fund in Europe may give rise to ongoing AIFMD disclosure obligations.