Politicians and regulators might want to consider requiring governmental issuers and their employees to follow the same standards of conduct that apply to private issuers and their employees.

The argument that States should find ways to encourage retirement planning should be separated from the argument over who should manage the plans. Is there any reason to believe that State-employed managers would do a better job at managing assets than private-sector managers, particularly given the very substantial existing regulation of funds by the SEC?

Given that out-of-the-country bad guys are unlikely to be much deterred by this penalty, and that cyber-protections of news agencies are outside of the corporate issuers' control, issuers should take this enforcement action as a precaution to consider the timing of their distribution of press releases. There seems to be no assurance that such releases can be kept protected until their official distribution time.

A comment published in 2013 in the Guide to Hedge Fund Regulation captured the prevailing view of Form PF at that time.

[M]any of the questions in Form PF are horrendously written with the result that it is not entirely clear that the Form is even getting at useful information. Even if the information might be useful, funds will inevitably answer the questions in quite different ways, making the information far less useful than it might have been if the Form were better…