(Article from Registered Funds Regulatory Update, July 2026)
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On April 20, 2026, the SEC and CFTC jointly proposed amendments to Form PF that are intended to reduce the reporting burdens on private fund advisers while preserving the collection of information the agencies deem necessary and appropriate for investor protection purposes. Form PF is a confidential reporting form applicable to certain SEC-registered investment advisers to private funds, including advisers that are also registered with the CFTC as commodity pool operators or commodity trading advisers. According to the agencies, prior rounds of rulemaking rendered the form unduly complex and costly for many firms to complete, without yielding data of commensurate regulatory utility. SEC Chair Atkins stated that the earlier requirements distracted advisers “from their core investment functions, often without a commensurate benefit to regulators’ use of the collected data.”
The proposed amendments would increase the threshold for advisers required to file Form PF from those managing $150 million in private fund assets to those managing $1 billion, which is estimated to eliminate the filing obligations for approximately half of the advisers currently required to file Form PF. The proposal further estimates that, even with the higher threshold, Form PF would continue to capture information concerning more than 90% of the gross assets of private funds reported by advisers. In addition, the proposal would eliminate certain reporting obligations for smaller hedge fund advisers by increasing the threshold for large hedge fund adviser status—which triggers more detailed quarterly reporting—from $1.5 billion to $10 billion in hedge fund assets under management. This change is estimated to eliminate certain reporting obligations for approximately two-thirds of the advisers that currently report as large hedge fund advisers.
Beyond narrowing the scope of filers, the proposal also streamlines the reporting requirements. For private equity fund advisers, the proposal would eliminate quarterly event reporting in its entirety. For large hedge fund advisers that remain within scope, it would remove or simplify a number of granular disclosure requirements, including certain counterparty exposure tables, performance volatility metrics, and obligations to “look through” fund structures in order to report indirect holdings. In addition, the proposal would afford hedge fund advisers the full 72-hour filing period for urgent event reports, rather than requiring such reports to be filed “as soon as practicable.”
Public comments on the proposed amendments were due June 23, 2026.
Form PF; Reporting Requirements for All Filers, SEC Release No. IA-6959; File No. S7-2026-13 (Apr. 20, 2026), available at: https://www.sec.gov/files/rules/proposed/2026/ia-6959.pdf.