Peirce Supports Form PF Amendment Proposal

Statement

“PF” Stands for Please Fix: Statement on the Proposed Amendments to Form PF

Commissioner Hester M. Peirce

April 20, 2026

Today, the Commission and the Commodity Futures Trading Commission (“CFTC”) (collectively, “Commissions”) proposed amendments to eliminate certain Form PF filing and reporting obligations and to streamline others. My thanks to the hardworking staff in the Division of Investment Management, Division of Economic and Risk Analysis, and Office of the General Counsel and to the CFTC for their work on this proposal. I support this proposal and hope to receive robust feedback from investors, investment advisers, private funds, and other interested parties.

I have been hearing calls to fix Form PF since I started as a commissioner. Form PF generates a lot of data at great expense that does not present a useful window into private fund activity. To date, the Commissions’ response to these pleas has been to make the form more—rather than less—onerous. The granular data required by the 2024 amendments, for example, made an already problematic form worse, as commenters warned would happen. [1] The fundamental problem with Form PF is that it has wandered from its core purpose: generating information to assist FSOC in identifying and monitoring risks to the financial stability of the United States. [2]

Many of today’s proposed amendments acknowledge and address the concerns we have heard. If adopted, these amendments should help to restore Form PF to its intended purpose. I urge commenters to look closely at both the proposed changes and what is not changing so that you can tell us whether additional or alternative changes would better restore the form to its intended role. I would welcome feedback on, among other questions, the following:

• The filing threshold for private fund advisers and the reporting threshold for large private fund advisers have not changed since the thresholds were adopted in 2011. Yet, as noted in the proposing release, the aggregated private fund gross asset value has more than tripled since 2013. [3] In addition, when we adopted the  large private fund adviser reporting thresholds we noted that they were designed so that the group of large private fund advisers (including large hedge fund advisers) filing Form PF would be relatively small in number but represent a substantial portion of the assets of their respective industries. [4] The number of overall private fund adviser filers and the number of large private fund advisers have grown because the thresholds have not changed since they were adopted.  The proposed amendments include an increase to the filing threshold for Form PF filers and the reporting threshold for large hedge fund advisers. Should we update other Form PF thresholds as well? Should we adopt amendments to require that these thresholds be updated periodically to account for inflation and industry changes?
• The Commissions are proposing to pare back some of the 2024 amendments and other information currently required by Form PF. Do these changes align Form PF with its systemic risk purpose? Are other changes necessary? Should we, for example, eliminate questions 42 and 43 rather than slimming them down?
• What information required by Form PF is useful in monitoring systemic risk and, conversely, what information is not?
• For information that is or might be useful, do the benefits to FSOC and the Commissions of having that information outweigh the costs incurred by funds and advisers in compiling and reporting that information? Now is the time to tell the Commissions what we got right and where we have gone astray.

[1] See, e.g., Comment Letter of the U.S. Chamber of Commerce (Oct. 11, 2022) at 4 (“The amendments under consideration represent a significant rewrite of Form PF and would require funds to provide extensive new streams of data unrelated to systemic risk.”), available at https://www.sec.gov/comments/s7-22-22/s72222-20145434-310656.pdf.

[2] See Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law 111–203, 124 Stat. 1376 (2010). Pursuant to the Dodd-Frank Act, the Investment Advisers Act of 1940 was amended to require that  an adviser must maintain records and reports for each private fund it advises, that include a description of the following: (1) the amount of assets under management and use of leverage, including off-balance-sheet leverage; (2) counterparty credit risk exposure; (3) trading and investment positions; (4) valuation policies and practices of the fund; (5) types of assets held; (6) side arrangements or side letters, whereby certain investors in a fund obtain more favorable rights or entitlements than other investors; (7) trading practices. The statute also allows the Commissions to require the disclosure of other information, including for investor protection purposes, but the statute’s primary objective is to inform the Financial Stability Oversight Council, which—as its name suggests—has a systemic risk monitoring and mitigation mandate.

[3] Form PF; Reporting Requirements for All Filers, Investment Advisers Act Release No. 6959 (Apr. 20, 2026) at 15, available at https://www.sec.gov/files/rules/proposed/2026/ia-6959.pdf.

[4] Id. at 22.

Last Reviewed or Updated: April 20, 2026