External Meetings: Meeting w/ Private Equity Growth Capital Council

PEGCC discussed its February 10, 2014 comment letter  on Aggregation of Positions, including recommendations for: a notice filing process for an aggregation exemption, including the frequency and timing of such notices; and fund (owner) certification in lieu of board member certification. Topics also discussed were:  the utility of conditioning aggregation relief on consolidation not being required under GAAP; a recommendation that appropriate sanctions (e.g., for manipulation or disruptive trading) be imposed, but that a penalty box disqualification from aggregation relief was not practicable; and a request for clarification of aggregation requirements regarding contracts subject to exchange limits, but not subject to federal limits.