DID YOU KNOW? Without the Family Office Rule, single family offices would be subject to even 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.
DID YOU KNOW? 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? Letter rulings issued by the CFTC in 2012 and 2014 exempt single family offices from registering as commodity pool operators and commodity trading advisers. In 2018, the CFTC issued proposed rules to codify these exemptions in a permanent rule that single family offices may rely upon. PIC ACTION: PIC obtained the original relief and was the primary advocate for the codification of these exemptions, including coordinating a comment letter campaign of its membership to expand the coverage of the final CFTC rule.
WHY JOIN PIC?
PIC is the recognized authority on both legislative and regulatory issues affecting single family offices, as well as 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.
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.
Advocated in the Senate for adoption of the Family Office Technical Correction Act H.R. 3972. The bill would have deemed 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 a provision excluding estates and trusts from the new, 20-percent pass-through deduction in the final tax reform legislation.
2016 Co-sponsored study highlighting the negative impact increasing estate tax valuations would have on family businesses. Joined the broader family business community in opposing this Treasury Department rule.
2015 Established the PIC Political Action Committee (PIC PAC) to coordinate bi-partisan 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 accomplish 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.
FINRA – Obtain clarification regarding Rules 5130 & 5131 in order to 1) expand the scope of the exemption for portfolio managers of family investments, 2) exclude certain non-profit companies from the definition of “covered non-public company,” and 3) expand the scope of the funds exemption.
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, as well as with 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.
ANNUAL MEETING (June 3 & 4, 2019)
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 to PIC members and invited guests only, and features an impressive line-up of key elected officials, top regulators, and other experts speaking on the topics of most interest to you and your family office. Celebrating our Tenth Anniversary in 2019, the event on June 3rd and 4th in Washington, DC will be the best Annual Meeting yet.
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 to PIC members include:
For more information about PIC membership, please contact:
Susan R. Murdock
Private Investor Coalition
You can learn more about PIC from our public website at: