SEC and CFTC Propose Scaling Back Form PF Requirements

On April 20, 2026, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) (collectively, the “Commissions”) jointly proposed amendments to Form PF that would substantially reduce reporting obligations for many private fund advisers (the “Proposed Amendments”). The Proposed Amendments would raise the filing threshold for all Form PF filers from $150 million to $1 billion in private fund assets under management (AUM) and increase the “large hedge fund adviser” threshold from $1.5 billion to $10 billion in hedge fund AUM. The Commissions also proposed to eliminate, streamline, or simplify a range of reporting requirements that advisers have viewed as especially burdensome. The key proposed changes are discussed in more detail below.

Background

Form PF has been amended multiple times, including substantively in 2023 and 2024. In 2024, the Commissions adopted broad amendments to Form PF, but delayed the compliance date several times, most recently to October 1, 2026.

The Proposed Amendments reflect a broader reconsideration of the 2024 Form PF amendments. According to the proposing release, the Commissions undertook a comprehensive review of Form PF in light of market feedback and a Presidential Memorandum directing agencies to review pending rules that raised substantial questions of fact, law, or policy.

Key Proposed Changes

If adopted, the Proposed Amendments would (among other things):

• Raise the Form PF filing threshold for all filers from $150 million in private fund AUM to $1 billion. The Commissions estimate that this change would eliminate filing obligations for almost half of current filers, while still capturing approximately 94% of private fund gross asset value reported by SEC-registered advisers. The SEC also proposed requiring its staff to report to the Commission on the filing threshold and each reporting threshold approximately five years after the compliance date for the amendments, and approximately every five years thereafter.
• Raise the threshold for “large hedge fund adviser” status from $1.5 billion in hedge fund AUM to $10 billion. Advisers falling below the new threshold would no longer be subject to Section 2 reporting or Section 5 current reporting solely because of their hedge fund assets. The SEC likewise proposed periodic staff review of the reporting thresholds on the same approximately five-year cycle.
• Revise General Instructions to permit advisers to treat certain feeder funds as “disregarded” if they hold no more than 5% of gross asset value outside a single master fund, U.S. Treasury bills, and/or cash and cash equivalents.
• Eliminate the prescriptive “look through” requirements for certain indirect exposure reporting and instead permit reasonable estimates consistent with internal methodologies and service-provider conventions.
• For advisers that remain large hedge fund advisers under the proposed $10 billion threshold, eliminate or simplify several questions added or revised in recent amendments, including:
• elimination of the requirement to report the value of positions at the end of the reporting period;
• elimination of adjusted exposure reporting based on internal methodologies;
• elimination of reporting regarding monthly asset turnover;
• simplification of reporting on industry concentration by allowing reporting at a less granular North American Industry Classification System (NAICS) level;
• elimination of requirements to include detailed information about monthly portfolio exposure to reference assets, and instead include streamlined exposure reporting under an existing extraordinary loss current report trigger;
• simplification of counterparty exposure reporting; and
• elimination of rehypothecation reporting, which requires large hedge fund advisers to report the percentage of the total amount of collateral and other credit support that counterparties have posted to the reporting fund that may be rehypothecated and that the reporting fund has been rehypothecated.
• Narrow certain current reporting for large hedge fund advisers, including by:
• removing the requirement to file “as soon as practicable” and instead requiring filing no later than 72 hours after the reportable event;
• eliminating current reporting for margin default or inability to meet a margin call;
• narrowing the definition of “operations event”; and
• eliminating current reporting triggered solely by inability to satisfy redemption requests, while retaining reporting for certain redemption suspensions.
• Eliminate quarterly event reporting for private equity fund advisers. If adopted, advisers would no longer be required to file quarterly reports concerning adviser-led secondary transactions, general partner removals, terminations of investment periods, or fund terminations. The proposing release states that the SEC has found these reports less impactful than expected for investor protection and systemic risk monitoring.

Requests for Comment on Private Credit

The Commissions also requested comment on whether to modify the information advisers report about private credit funds on Form PF, noting the significant growth of the private credit industry since Form PF’s adoption in 2011.

Looking Ahead

Comments on the Proposed Amendments are due on or before June 23, 2026. If the Proposed Amendments are adopted, the Commissions proposed a minimum 12-month transition period for compliance, with some filers having longer to accommodate their reporting cycle.

In the proposing release, 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 Form PF amendments. Private fund advisers should continue to monitor developments closely, as that timing could materially affect compliance planning.

If you have any questions regarding this client alert, please reach out to your usual MoFo contact or the authors.