The PEGCC and Public Policy

The Private Equity Growth Capital Council (PEGCC) works to promote public policies that encourage the continued growth of the private equity (PE) investment community and protect the investments in private equity funds made by pension funds, university endowments, charitable foundations and all other limited partners. Current issues on which the PEGCC has taken a position include:

• The tax treatment of “carried interest” profit shares for PE general partners
• The Dodd Frank Act and the Volcker Rule
• The laws governing publicly-traded partnerships.

Legislative Statements and Testimony

The PEGCC and its staff of experts provide information and input to elected officials related to pending legislation.

• Long-Term Commitments: The Interdependence of Pension Security and Private Equity - May 9 2013
• PEGCC Comment Letter on Carried Interest - April 15 2013
• PEGCC Comment Letter on Flow-Through (Pass-Through) Taxation - April 15 2013
• Carried Interest – Fact v. Fiction - December 18 2012
• Private Equity Council testimony before Senate Banking Subcommittee - July 15 2009
• The GAO, Private Equity and Pension Fund Investments - September 15 2008
• PEC Testimony Before the House Committee on Energy and Commerce Subcommittee on Telecommunications and the Internet on March 11, 2008. - March 11 2008
• Private Equity Council statement on tax legislation approved by House of Representatives - November 9 2007
• Private Equity Council issues statement on tax legislation approved by House Committee on Ways and Means - November 1 2007
• PEC statement on tax legislation proposed by Ways and Means Chairman Rangel - October 25 2007
• PEC testimony before the House Ways and Means Committee - September 6 2007
• PEC testimony before the Senate Finance Committee - July 31 2007
• Private Equity and Carried Interest - House - July 10 2007
• Private Equity and Publicly-Traded Partnerships - S 1624 - July 10 2007
• PEC testimony before House Financial Services Committee - May 16 2007
• Private Equity and the Treatment of Carried Interest: An Overview - May 4 2007

Regulatory Comment Letters and Testimony

The PEGCC regularly comments on regulatory notices, statements and related materials to provide the viewpoint of the private equity industry to regulators, policy makers and other relevant parties in the United States and around the world.

United States Comment Letters

• PEGCC Supplemental Comments to the CFTC on the Disaggregation Proposal - August 20 2012
• PEGCC Comments to the CFTC on the Disaggregation Proposal - June 29 - July 29 2012
• PEGCC Comments on the proposed “Leveraged Lending Guidance” June 8 2012 - June 8 2012
• PEGCC FATCA Comment letter - April 30 2012
• PEGCC Comments to the US Treasury on the Proposed Rule Regarding Assessment of Fees on Large Bank Holding Companies and Nonbank Financial Companies Supervised by the Federal Reserve Board to Cover the Expenses of the Financial Research Fund - March 5 2012
• PEGCC Comments on Proposed Regulations Implementing the Volcker Rule - February 13 2012
• PEGCC Comments to the Financial Stability Oversight Council on the "Second Notice of Proposed Rulemaking Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies" - December 16 2011
• PEGCC Comments to the Securities and Exchange Commission on “Incentive Compensation” - May 31 2011
• PEGCC Comments in Advance of Notice of Proposed Rulemaking Implementing the Private Funds Portion of the Volcker Rule - May 10 2011
• PEGCC Comments to the Securities and Exchange Commission on “Listing Standards for Compensation Committees” - April 28 2011
• PEGCC Comments to the Securities and Exchange Commission on “Form PF” - April 12 2011
• PEGCC Comments to the Federal Reserve Board on Proposed Definition of “Significant Nonbank Financial Company” - March 30 2011
• PEGCC Comments to the Financial Stability Oversight Council on “Notice of Proposed Rulemaking Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies” - February 25 2011
• PEGCC Comments to the Financial Stability Oversight Council on “Request for Public Input for the Study Regarding Implementation of the Prohibitions on Proprietary Trading and Certain Relationships with Hedge Funds and Private Equity Funds” - November 5 2010
• PEGCC Comments to the Financial Stability Oversight Council on “Advance Notice of Proposed Rulemaking Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies” - November 5 2010
• PEGCC Comments to the FTC on Hart-Scott-Rodino Form Changes - October 18 2010
• PEC Comments to the Federal Deposit Insurance Corporation on “Proposed Statement of Policy on Qualifications for Failed Bank Acquisitions” - August 6 2009
• PEC Comments to the Securities and Exchange Commission on “Custody of Funds or Securities of Clients by Investment Advisers” - July 28 2009
• PEC Comments to the SEC on “Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles; Accredited Investors in Certain Private Investment Vehicles.” - March 9 2007

Foreign Comment Letters

• PEGCC Comment Letter on Germany AIFMD Proposed Legislation - October 9 2012
• PEGCC and AVCAL Kuwait Comment Letter - June 28 2011
• PEGCC and AVCAL Comment Letter to ESCA on Draft Investment Fund Regulation - February 25 2011

Joint Comments on the OECD’s Draft High Level Principles of Long-Term Investment Financing

• PEGCC, EVCA, and NVCA Joint Cover Letter - May 24 2013
• Comments on the OECD Principles of Long-Term Financing - May 24 2013
• Long-Term Investment: The Private Equity Contribution - May 24 2013