SEC and CFTC Propose Form PF Amendments
On April 20, 2026, the SEC and CFTC jointly proposed amendments to Form PF designed to reduce reporting burdens on private fund advisers while preserving the data needed for systemic risk monitoring. The proposal is significant in scope: it would exempt approximately half of current Form PF filers entirely and substantially streamline what remains.
What Would Change
Two threshold changes drive most of the impact. First, the general filing threshold would rise from $150 million in private fund assets under management to $1 billion. Advisers below the new threshold would no longer be required to file Form PF at all. Second, the exposure reporting threshold for “large” hedge fund advisers would rise from $1.5 billion in hedge fund assets under management to $10 billion. The agencies state that even after these changes, Form PF would continue to capture more than 90 percent of private fund gross assets and would retain detailed exposure information for funds managed by the largest hedge fund advisers.
Beyond the threshold changes, the proposal would eliminate or streamline a number of specific Form PF requirements throughout the form. The proposal would also add a method for identifying funds active in the private credit market.
Why This Matters
SEC Chairman Atkins framed the proposal as a return to balance and a reduction in compliance cost, observing that prior amendments had produced disclosure obligations “often without a commensurate benefit to regulators’ use of the collected data.” CFTC Chairman Selig emphasized that raising the thresholds is a way to relieve smaller filers without compromising data needed by FSOC.
For the adviser community, the practical effect, if finalized, would be a meaningful reduction in ongoing compliance costs for the substantial portion of advisers managing between $150 million and $1 billion in private fund assets. Advisers in that range should plan ahead but not change current behavior. The proposal is a notice of proposed rulemaking, and its 60-day public comment period begins on publication in the Federal Register. Existing Form PF requirements remain in effect until the SEC and CFTC adopt a final rule and that final rule takes effect.
What Advisers Should Do Now
Three steps are reasonable in the near term. First, continue to file under existing requirements. The May 29 deadlines for large hedge fund advisers, PE event reports, and CPO Form PQR are unchanged. Second, consider whether the firm has practical experience with Form PF that would be useful in a comment letter. The agencies have explicitly invited input on whether the proposed amendments are calibrated correctly. Third, advisers expecting to fall below the new thresholds should not yet remove Form PF filing procedures from their compliance programs. The proposal could be modified before adoption, and the timing of any final rule is uncertain.
Takeaways
- The general Form PF filing threshold would rise from $150 million to $1 billion in private fund assets under management.
- The large hedge fund adviser exposure reporting threshold would rise from $1.5 billion to $10 billion.
- Approximately half of current Form PF filers would be exempt from the form entirely if the proposal is adopted as written.
- Existing Form PF requirements remain fully in effect. Continue to file under current rules until any final rule takes effect.
- A 60-day public comment period will open on publication in the Federal Register. Advisers with practical Form PF experience should consider commenting.