The Collective Voice for Single Family Offices
DID YOU KNOW? Without the Family Office Rule, single family offices would be subject to greater inspection and registration requirements of the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), including having to register as investment advisors. PIC ACTION: PIC worked directly with Congress and the SEC to create the Family Office Rule to preserve the privacy of families, individual family members, and single family offices (SFOs).
DID YOU KNOW? PIC represents family offices on key tax policies before Congress and Treasury? For example, initial drafts of the Tax Cuts and Jobs Act would have imposed a punitive, “first‐In, first‐out” rule for determining the basis of stock sales and would have unfairly excluded estates and trusts from the new, 20‐percent pass‐through deduction. PIC ACTION: PIC mobilized its membership and worked with other trade groups to successfully strike these harmful provisions from the final bill.
DID YOU KNOW? Family offices have numerous regulatory compliance obligations related to SEC, CFTC, FINRA and Treasury Department rules. PIC ACTION: PIC serves as a resource for its members on regulatory compliance obligations, hosts regular Member calls with compliance experts, and provides access to a network of experts who can provide up‐to‐date guidance.
DID YOU KNOW? PIC serves not just as a resource on regulatory matters but as an advocate as well? PIC ACTION: In recent years, PIC has successfully advocated numerous improvements to the rules imposed on family offices by the SEC, CFTC, FINRA and Department of Treasury.
WHY JOIN PIC?
- Your family will be alerted to public policy issues that affect SFOs.
- Your family will have a voice in Washington, helping to shape many regulatory and tax policies that directly affect SFOs.
- Your family will have a resource for compliance concerns.
- Your family will have an opportunity to advocate for policy positions alongside other families that share your concerns and interests.
- Your family will enjoy peer‐to‐peer networking opportunities, expanding their knowledge base, and educating them about best practices in a unique and trusted network.
PIC is the recognized authority on legislative and regulatory issues affecting single family offices and the primary resource for disseminating information on compliance matters.
MEMBERSHIP AND DUES
PIC membership is exclusive to single family offices and high net worth families. Annual dues are $10,000 per calendar year. PIC strives to keep dues to a minimum while ensuring that we have the necessary resources to effectively represent single family offices before Congress and the multiple regulatory agencies with jurisdiction over family office activities.
A volunteer board of directors composed of senior SFO executives and family principals manage the policies and priorities of PIC. PIC is organized under section 501(c)(6) of the Internal Revenue Code.
2019 Successfully advocated with FINRA and the SEC for adoption of amendments to ease family office participation in the Purchase and Sale of Initial Public Equity Offerings (Rule 5130) and New Issue Allocations and Distributions (Rule 5131). PIC’s advocacy effort with FINRA in this area began in 2015.
Won permanent relief for family offices when the CFTC exempted them from registration and compliance requirements for Commodity Pool Operators and Commodity Trading Advisers. These permanent exemptions are the culmination of years of work and were a top priority for PIC. PIC’s comment letter was cited extensively by the CFTC in the Final Rule analysis.
2018 Following years of PIC advocacy, the CFTC published proposed rules to codify Family Office exemptions from registration requirements as Commodity Pool Operators and Commodity Trading Advisers.
Pressed the Senate to adopt the Family Office Technical Correction Act (H.R. 3972). The bill would deem any “family office” or “family client,” to be an accredited investor under the Securities Act of 1933. It passed the House of Representatives by unanimous voice vote in 2017.
2017 Successfully advocated for striking a punitive, “first‐In, first‐out” rule for determining the basis of stock sales and excluding estates and trusts from the new, 20‐percent pass‐through deduction from tax reform. The final law excluded both these harmful provisions.
2016 Co-sponsored a study highlighting the negative impact higher estate tax valuations would have on family businesses. Joined the broader family business community to successfully oppose this Treasury Department rule.
2015 Established the PIC Political Action Committee (PIC PAC) to coordinate bipartisan contributions in the SFO community.
2014 Successfully petitioned the CFTC for No‐Action relief for family offices as Commodity Trading Advisers.
2012 Successfully petitioned the CFTC for No‐Action relief for family offices as Commodity Pool Operators.
2011 Successfully worked with the SEC on the formulation of the Family Office Rule.
2010 Successfully led the initiative under Dodd‐Frank to exempt family offices from SEC registration as investment advisers.
The PIC Board sets the priorities of the organization and works in concert with its membership and allies to achieve them, including:
Financial Services Reform – Work with Congress to amend the “Accredited Investor” definition and “Qualified Purchaser” definition to include any family client of a family office, as well as to include a new exemption for family offices and family clients from registration under the Investment Company Act.
Investment Expenses – Work with Congress and the Administration to restore the ability of family investors to deduct legitimate investment expenses from their returns on investment.
Regulatory Reform: Build on our success before the SEC, FINRA and CFTC to continue to ease the regulatory burdens imposed on family offices.
Alerts: Monitor and alert the PIC membership to proposed legislation and agency regulations that would, intentionally or otherwise, disproportionately impact SFOs and the family members they serve.
Profile ‐ Continue to expand PIC’s relationships on Capitol Hill, key regulators and industry allies.
SFO Education – Continue to provide information and resources to help SFOs understand and meet their existing compliance and regulatory burdens.
In just a few years, the PIC Annual Meeting has become the “go‐to” event on the family office calendar. Held in Washington, DC in late spring, the Annual Meeting is open only to PIC members and invited guests and features an impressive line‐up of key elected officials, top regulators, and other experts speaking on the topics of interest to you and your family office. PIC celebrated its Tenth Anniversary in 2019 with the best Annual Meeting yet. Mark your calendar for PIC’s 2020 annual meeting on April 20 and 21.
If you are a single family office or individual private investor and are interested in learning more about membership in PIC, then let’s have a conversation. Benefits include:
- Real‐time direct source information on legislative and regulatory issues impacting single family offices;
- Regulatory compliance notifications covering single family offices;
- Updates and alerts regarding public policy initiatives of significance to single family offices;
- Direct access to public policy decision makers;
- Attendance at PIC Annual Meeting in Washington, DC;
- Access to PIC web site content; and
- Access to the PIC PAC.
For more information about PIC membership, please contact:
Private Investor Coalition Office: 202-508-1473
You can learn more about PIC from our public website at: