SEC and CFTC Propose Form PF Amendments, Raise Thresholds to $1B
Summary
The SEC and CFTC jointly proposed amendments to Form PF on April 24, 2026, seeking to raise the filing threshold for all Form PF filers from $150 million to $1 billion in private fund assets under management. The proposal would also raise the reporting threshold for large hedge fund advisers from $1.5 billion to $10 billion in hedge fund assets and eliminate quarterly event reporting for private equity fund advisers. Comments on the proposal must be submitted by June 23, 2026.
Investment advisers to private funds near the $150M–$1B assets under management range should begin assessing whether the proposed threshold increase would remove their Form PF filing obligations. Advisers currently filing as large hedge fund advisers between $1.5B–$10B in hedge fund assets should similarly evaluate whether they would be reclassified under the proposed threshold. The June 23 comment deadline provides an opportunity to submit data or operational concerns about current reporting burdens.
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What changed
The SEC and CFTC jointly proposed amendments to Form PF that would significantly raise reporting thresholds for investment advisers to private funds. The filing threshold for all Form PF filers would increase from $150 million to $1 billion in private fund assets under management, and the reporting threshold for large hedge fund advisers would increase from $1.5 billion to $10 billion in hedge fund assets. The proposal also includes elimination of certain reporting requirements such as performance volatility reporting, portfolio turnover reporting, and consolidated counterparty exposure tables, as well as removal of quarterly event reporting for private equity fund advisers.
Affected investment advisers to private funds, including those registered with the CFTC as commodity pool operators or commodity trading advisors, should monitor this proposal and consider submitting comments by the June 23 deadline. Advisers currently required to file Form PF near the $150 million threshold should evaluate whether they would fall out of scope under the proposed $1 billion threshold, which the agencies estimate would eliminate filing obligations for nearly half of advisers currently required to file.
Archived snapshot
Apr 27, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
April 27, 2026
SEC and CFTC jointly propose amendments to reduce Form PF reporting burdens
On April 24, the SEC and CFTC jointly proposed amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, including those also registered with the CFTC as commodity pool operators or commodity trading advisors. Form PF collects information designed to facilitate FSOC’s monitoring of systemic risk and is used by the SEC and CFTC in their investor protection efforts. The proposal follows a “comprehensive review” conducted in accordance with a January 2025 presidential memorandum directing agencies to halt all new and recently issued rules pending review, which prompted the agencies to delay the compliance date for 2024 Form PF amendments multiple times, most recently to October 1, 2026. SEC Chairman Paul Atkins stated that “[p]rior amendments to Form PF have led to overly burdensome disclosure requirements for advisers, distracting them from their core investment functions, often without a commensurate benefit to regulators’ use of the collected data.”
The proposed amendments would, among other things:
- Raise the filing threshold for all Form PF filers from $150 million to $1 billion in private fund assets under management, which the agencies estimate would eliminate filing obligations for nearly half of the advisers currently required to file while continuing to capture over 90 percent of private fund gross asset value
- Raise the reporting threshold for “large” hedge fund advisers from $1.5 billion to $10 billion in hedge fund assets under management, eliminating certain reporting obligations for almost two-thirds of advisers currently filing as large hedge fund advisers while continuing to obtain quarterly information on over 80 percent of hedge fund gross asset value
- Eliminate or streamline numerous existing requirements, including certain “look through” requirements, performance volatility reporting, portfolio turnover reporting, rehypothecation reporting, and the consolidated counterparty exposure table for qualifying hedge funds
- Eliminate certain current reporting triggers for large hedge fund advisers, including reports for margin defaults and inability to satisfy redemption requests, and modify the filing deadline by removing the “as soon as practicable” requirement so advisers would have a full 72 hours to file
- Eliminate quarterly event reporting for all private equity fund advisers
- Enable a method to identify funds active in the private credit market Comments on the proposal must be submitted by June 23.
[View source.]
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Orrick, Herrington & Sutcliffe LLP
2026
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