Overview

In April 2026, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) jointly proposed significant amendments to Form PF, the confidential reporting form required for certain SEC-registered investment advisers to private funds. The proposal is intended to reduce compliance burdens, simplify reporting obligations, and recalibrate filing thresholds while continuing to provide the Financial Stability Oversight Council (“FSOC”) and regulators with sufficient information to monitor systemic risk.

The proposal largely revisits and rolls back portions of the extensive 2023 and 2024 Form PF amendments, many of which had not yet become effective due to repeated compliance-date extensions. The agencies emphasized that the private fund industry has grown substantially since Form PF was originally adopted in 2011, and that their experience reviewing more than a decade of Form PF data supports narrowing the population of required filers and streamlining reporting requirements.

Key Proposed Changes

1. Increase in Filing Threshold for All Form PF Filers

The proposal would increase the minimum filing threshold for all Form PF filers from $150 million to $1 billion in private fund assets under management.

The agencies estimate this change would eliminate filing obligations for approximately 43% of advisers currently required to file Form PF, while still capturing approximately 94% of total private fund gross asset value reported by SEC-registered advisers.

The SEC and CFTC believe this change would better focus reporting obligations on larger advisers that are more relevant to systemic risk analysis while reducing compliance burdens for smaller advisers.

Importantly, advisers that fall below the new Form PF threshold would still remain subject to Form ADV reporting obligations and Advisers Act recordkeeping requirements.

2. Increase in Large Hedge Fund Adviser Threshold

The proposal would also increase the threshold for “large hedge fund advisers” from $1.5 billion to $10 billion in hedge fund assets under management.

Under the current framework, large hedge fund advisers are subject to:

• Quarterly Form PF filings;

• Detailed Section 2 reporting; and

• Current reporting obligations under Section 5 for specified stress or liquidity events.

The agencies estimate the revised threshold would reduce the number of advisers qualifying as large hedge fund advisers by approximately 65%, while still capturing more than 80% of hedge fund gross asset value.

Advisers that no longer meet the revised threshold would generally revert to annual reporting and would no longer be subject to Section 2 or Section 5 current reporting requirements.

3. Elimination and Streamlining of Reporting Requirements

The proposal contains numerous revisions intended to simplify reporting obligations and reduce operational burden. Key changes include:

Feeder Fund Reporting

The agencies propose allowing advisers to treat certain feeder funds as “disregarded feeder funds” if no more than 5% of gross asset value is invested outside a single master fund, U.S. Treasury bills, or cash equivalents.

This change would permit aggregation rather than separate reporting for many master-feeder structures.

Elimination of Prescriptive “Look-Through” Requirements

The proposal would remove mandatory “look-through” reporting requirements for indirect exposures through other funds and entities.

Instead, advisers could use reasonable estimates consistent with their internal methodologies and service provider conventions.

This change responds to industry concerns that detailed look-through reporting for ETFs, private funds, and complex investment structures would be operationally burdensome and difficult to implement.

Trading Vehicle Reporting

The proposal would narrow the universe of trading vehicles that must be separately identified on Form PF.

Volatility and Exposure Reporting

The agencies propose eliminating several detailed quantitative reporting requirements, including:

• Question 23(c) volatility reporting;

• Certain adjusted exposure reporting based on internal methodologies;

• Monthly asset turnover reporting;

• Certain trading and clearing position reporting; and

• Rehypothecation reporting.

The proposal also would simplify counterparty exposure reporting and industry concentration reporting (including reduced NAICS code specificity requirements).

4. Changes to Current Reporting Requirements

The SEC proposes several significant revisions to Section 5 current reporting obligations applicable to large hedge fund advisers.

Filing Deadline Flexibility

Currently, advisers must file current reports “as soon as practicable, but no later than 72 hours.”

Under the proposal, advisers would have the full 72-hour period to submit current reports.

Elimination of Certain Current Reporting Triggers

The SEC proposes eliminating current reporting requirements related to:

• Margin defaults or inability to meet margin calls;

• Certain redemption inability events; and

• Certain operational disruption events.

The proposal would also streamline reporting related to extraordinary investment losses.

5. Elimination of Private Equity Quarterly Event Reporting

The SEC proposes eliminating Section 6 quarterly event reporting requirements for private equity fund advisers.

These reporting obligations, adopted in 2023, currently require reporting of:

• Adviser-led secondary transactions;

• GP removals;

• Termination of investment periods; and

• Fund terminations.

The SEC stated that removing these requirements would significantly reduce compliance burdens.

Regulatory Rationale

The agencies emphasized that the proposal is intended to recalibrate Form PF reporting requirements after more than a decade of industry growth and regulatory experience.

The proposal follows a broader 2025 regulatory review initiated after a Presidential Memorandum directing agencies to reassess pending regulations that raised substantial policy or operational concerns.

Throughout the release, the SEC and CFTC repeatedly state that the amendments are designed to:

• Eliminate unnecessary reporting burdens;

• Improve operational feasibility;

• Better align reporting with advisers’ actual risk management practices; and

• Preserve sufficient data collection for systemic risk monitoring.

Practical Implications for Advisers

If adopted, the proposal would materially reduce Form PF compliance obligations for many private fund advisers, particularly:

• Smaller private fund advisers;

• Mid-sized hedge fund advisers;

• Advisers with complex master-feeder structures; and

• Advisers that currently rely on burdensome indirect exposure calculations.

Advisers currently preparing for compliance with the delayed 2024 Form PF amendments may need to reassess implementation efforts pending final rulemaking.

The proposal remains subject to public comment, and the agencies specifically requested feedback on alternative threshold levels, inflation-adjustment mechanisms, and whether additional changes should be made to private credit fund reporting.

The current compliance date for the 2024 amendments remains October 1, 2026 unless further modified through subsequent rulemaking.

For more information about the SEC Form PF filing, please contact Caroprese via e-mail to info@caroprese.com.