SEC and CFTC Propose to Amend Scope and Requirements for Form PF

Author: Erin Van Den Berghe

On April 20, 2026, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) issued a joint proposal (“Proposal”) that would substantially revise Form PF reporting obligations for private fund advisers. The Proposal represents both a meaningful shift away from the expanded reporting framework adopted in 2024, previously expected to go into effect on October 1, 2026, as well as a substantial reduction of the scope of reporting obligations currently in effect.

Highlights of the Proposed Changes

If adopted as currently written, the Proposal would significantly narrow the scope of advisers required to file Form PF by raising key reporting thresholds. Per its terms, advisers would only be required to file Form PF if they manage at least $1B in private fund assets under management (“AUM”), a substantial increase from the current $150M threshold. In addition, the definition of a “large hedge fund adviser” would be revised upward from $1.5B to $10B in AUM, reducing the number of advisers subject to quarterly and trigger event reporting requirements.  

For advisers that remain subject to Form PF, the Proposal would eliminate or simplify many reporting items introduced in recent years. Among other changes, the Proposal would remove quarterly event reporting for private equity fund advisers, eliminate certain performance and turnover metrics, scale back mandatory “look-through” calculations, and dispense with reporting related to collateral rehypothecation, collateral reuse rights, margin defaults, and redemption stress events. The Proposal would also allow advisers to disregard certain feeder funds invested predominantly in a single master fund and would narrow the types of operational events that trigger reporting.

Why the Changes Matter

These proposed changes mark a clear recalibration of the Form PF regime by not only narrowing the scope of advisers subject to reporting, but also preemptively unwinding much of the 2024 expansion before it takes effect. The higher reporting thresholds are expected to remove a substantial number of smaller and mid-sized advisers from Form PF obligations altogether, while still allowing regulators to collect data covering the vast majority of private fund assets – reducing reporting coverage of private fund gross asset value across SEC-registered advisers by only 2%.  

For advisers that remain within scope, the elimination of certain event-driven and highly granular reporting requirements would materially reduce the ongoing compliance burden associated with reporting. More broadly, the SEC and CFTC emphasize that the revised approach is intended to preserve core information relevant to risk monitoring while removing data points that have proven difficult for advisers to implement or are of limited value to regulators.  

Key Takeaways  

If adopted as proposed, the increased asset thresholds will preclude many private fund advisers from Form PF filing requirements. Hedge fund advisers would see a reduction both in the number of firms classified as “large” and in the scope of ongoing reporting for those that remain subject to enhanced requirements. Private equity advisers would receive substantial relief through the elimination of quarterly event reporting.  

At the same time, private credit managers – specifically mentioned in the request for public comment – should closely monitor developments for potential future regulatory focus in that area. Advisers should also remain mindful that the 2024 Form PF amendments currently remain scheduled to take effect on October 1, 2026, unless superseded by final action on the Proposal in the interim.