SEC and CFTC Jointly Propose Amendments to Form PF That Would Raise Reporting Thresholds and Reduce Burdens

Executive Summary

On April 20, 2026, the SEC and the CFTC (the “Commissions”) jointly proposed amendments to Form PF that would eliminate or reduce Form PF filing obligations for a significant portion of private fund advisers (the “Proposed Amendments”).^[1] The Proposed Amendments would:

1. raise the Form PF filing threshold for all filers from $150 million to $1 billion in “private fund assets under management;”
2. raise the reporting threshold for “large hedge fund advisers” from $1.5 billion to $10 billion in “hedge fund assets under management;”
3. eliminate quarterly event reporting for private equity fund advisers;
4. narrow current event reporting for large hedge fund advisers; and
5. streamline various elements of the form by: eliminating certain “look through” requirements, eliminating certain performance volatility reporting requirements, simplifying certain large hedge fund counterparty exposure reporting and making corrections and other revisions.

The Proposed Amendments are designed to eliminate certain filing obligations, streamline reporting requirements and make corrections and other revisions to the form, all while ensuring Form PF continues to collect the information necessary and appropriate in the public interest and for the protection of investors. 

The Proposed Amendments are expected to receive industry support given the overall burden-reducing nature of the changes. However, it is important to remember that the starting point for the Proposed Amendments is the 2024 Form PF and not the current Form PF.  Instead of rolling back the 2024 Amendments entirely, the Commissions retained certain elements of the 2024 Amendments, while eliminating or modifying others. Advisers should carefully assess the implications of each proposed change-particularly those that introduce new or modified reporting obligations when compared to the current Form PF.

Key Takeaways

• Requests for Comment on Private Credit – The Commissions requested comments on whether to expand or replace existing reporting requirements with alternative reporting for private credit fund advisers and whether to separately define “private credit fund.” Although they did not propose additional private credit fund reporting, by requesting comments, the Commissions are preserving the flexibility to adopt it. Private credit fund advisers may wish to consider participating in the comment process to advocate for Form PF reporting that is better tailored to their investment strategies.
• 2024 Form PF Amendments Still Looming – Absent additional action from the Commissions, the compliance date for the 2024 Amendments remains October 1, 2026. The Commissions stated that they will consider how the timing of any amendments will relate to the October 1, 2026 compliance date for the 2024 Amendments. Private fund advisers should continue to monitor developments closely, as the interplay between the existing compliance deadline for the 2024 Amendments and the timeline for finalization of this proposal will impact compliance planning.

Discussion

Form PF has been substantively amended twice in the last few years, with both amendments increasing the burdens of reporting. On May 3, 2023, the SEC largely adopted its January 2022 proposed amendments to Form PF (the “2023 Amendments”), which, among other things, introduced current event reporting for large hedge fund advisers and quarterly event reporting for private equity fund advisers. On February 8, 2024, Form PF was comprehensively amended when the Commissions jointly adopted the August 2022 proposed amendments to Form PF (the “2024 Amendments”). While the 2023 Amendments have been implemented, the compliance date for the 2024 Amendments has been extended multiple times – most recently to October 1, 2026. Following a January 2025 Presidential Memorandum directing agencies to review rules not yet in effect, the Commissions conducted a comprehensive review of the entire form, and the Proposed Amendments are the product of that review. The Commissions used the 2024 Amendments as the baseline for the Proposed Amendments, retaining certain elements, while eliminating or modifying others.

If adopted, the Proposed Amendments would:[2]

• raise the filing threshold for all Form PF filers from $150 million to $1 billion in “private fund assets under management”, eliminating filing obligations for nearly half of the advisers currently required to file Form PF while continuing to capture approximately 94 percent of aggregate private fund gross asset value reported;
• raise the reporting threshold for “large hedge fund advisers” from $1.5 billion to $10 billion in “hedge fund assets under management,” discharging approximately two-thirds of advisers currently classified as large hedge fund advisers of enhanced reporting obligations while continuing to capture approximately 81 percent of hedge fund gross asset value reported;
• introduce a de minimis exception permitting advisers to disregard a feeder fund that does not invest more than five percent of its gross asset value in assets outside of a single master fund, U.S. treasury bills, and/or cash and cash equivalents, eliminating the separate reporting burden for feeder funds with minimal outside holdings;
• replace mandatory prescriptive “look through” requirements for reporting fund’s investments with a flexible standard, permitting advisers to report indirect exposures based on reasonable estimates consistent with their internal methodologies and the conventions of service providers;
• narrow the universe of trading vehicles that must be identified, focusing solely on trading vehicles that face counterparties and creditors or are reported on Form ADV as private funds, thus reducing the scope from the broad definition that potentially captured passive entities such as tax blockers, liability blockers, aggregator vehicles and passive holding companies;
• eliminate entirely requirements to report certain performance volatility-related information for advisers that calculate a market value on a daily basis for any position in the reporting fund’s portfolio;
• eliminate requirements for advisers to report the value of their reporting fund’s positions at the end of the reporting period when reporting how trading and clearing mechanisms are used;
• streamline requirements for large hedge fund advisers to report the adjusted exposure of long and short positions for each sub-asset class in which a “qualifying hedge fund”[3] has a reportable position;
• eliminate requirements that large hedge fund advisers report the value of turnover in certain asset classes in their qualifying hedge funds’ portfolios for each month during the quarterly reporting period;
• simplify monthly industry exposure reporting by giving large hedge fund advisers the flexibility to choose any level of NAICS classification, effectively reducing reporting of exposure data;
• eliminate requirements that large hedge fund advisers report details about their qualifying hedge funds’ monthly concentrated exposure to specific, position-level reference assets;
• simplify counterparty exposure reporting by large hedge fund advisers for their qualifying hedge funds;
• eliminate requirements that large hedge fund advisers to qualifying hedge funds report the total amount of collateral and other credit support that counterparties have posted to the reporting fund that may be and has been rehypothecated by the qualifying hedge fund;
• eliminate or narrow the scope of certain current reporting for large hedge fund advisers under Section 5, including:
  • eliminating current reporting for margin defaults;
  • eliminating current reporting for inability to satisfy redemption requests;
  • narrowing the definition of “operations event”; and
  • removing the requirement to file current event reports “as soon as practicable” while maintaining the 72-hour filing deadline;
• eliminate entirely Section 6 quarterly event reporting for all “private equity fund” advisers; and
• make certain corrections and other revisions aimed to help ensure filers more clearly understand Form PF requirements.

Next Steps

The Proposing Release was published on each Commission’s website on April 20, 2026, and will be published in the Federal Register. The public comment period will remain open for 60 days after publication in the Federal Register. The Commissions propose a minimum 12-month transition period from the date of publication in the Federal Register for filers to comply with the Proposed Amendments, if adopted, with some filers having longer to accommodate their reporting cycle. 

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[1] Form PF; Reporting Requirements for All Filers (April 20, 2026), available here (the “Proposing Release”).

[2] The Introduction section of the Proposing Release has tables summarizing the Proposed Amendments, including a description of current filing requirements and what changes will be made to the relevant General Instructions, Glossary of Terms, Sections, Items and Questions. See Proposing Release 11–14. 

[3] The Form PF Glossary defines “qualifying hedge fund” as “any hedge fund that has a net asset value (individually or in combination with any feeder funds, parallel funds and/or dependent parallel managed accounts) of at least $500 million as of the last day of any month in the fiscal quarter immediately preceding [an adviser’s] most recently completed fiscal quarter.”