Key Takeaways
- • The SEC and CFTC jointly proposed amendments to Form PF on April 20, 2026, designed to reduce private fund reporting burdens while maintaining systemic risk monitoring capabilities for the Financial Stability Oversight Council (FSOC).
- • The proposal raises the "large hedge fund adviser" threshold that triggers quarterly filing requirements, increasing it from the current $1.5 billion in hedge fund assets under management, significantly reducing compliance costs for smaller advisers who represent nearly half of all currently registered advisers.
- • The amendments eliminate filing requirements for smaller advisers and streamline disclosure obligations, including the elimination of private equity quarterly reporting requirements, rationaling Form PF scope to better align with regulatory purpose.
- • SEC Chairman Paul S. Atkins framed the changes as part of a broader agenda to restore balance to disclosure obligations and reduce compliance costs without sacrificing investor protection or systemic risk monitoring.
- • The proposal maintains Form PF's core function of collecting data for FSOC and supports SEC and CFTC investor protection efforts, while reducing unnecessary administrative burdens that had distracted advisers from core investment functions.
Summary
On April 20, 2026, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly announced proposed amendments to Form PF, the confidential reporting form required for SEC-registered investment advisers to private funds. The initiative represents a regulatory shift toward reducing compliance burdens that have accumulated through prior amendments, with SEC Chairman Paul S. Atkins stating that previous Form PF modifications had created "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 include several substantive modifications to the filing structure. The agencies propose raising the "large hedge fund adviser" threshold—which triggers quarterly filing obligations—from its current level of $1.5 billion in hedge fund assets under management. Additionally, the proposal would eliminate filing requirements for smaller advisers, a cohort representing approximately half of all currently registered advisers. Private equity quarterly reporting requirements would also be eliminated under the proposal, further streamlining disclosure obligations across the alternative fund industry.
Form PF serves dual regulatory purposes: it facilitates the Financial Stability Oversight Council's monitoring of systemic risk in financial markets and supports both the SEC and CFTC's investor protection efforts. The SEC and CFTC's coordinated approach, formalized through a March 11, 2026 memorandum of understanding establishing ongoing coordination frameworks, reflects institutional alignment on modernizing registration and reporting rules. CFTC Chairman Michael S. Selig emphasized that "by raising the filing threshold and streamlining Form PF, we are taking steps to reduce the burdens associated with filing the form," while noting the agencies would carefully review public comments during the rulemaking process.
The amendments are positioned within a broader regulatory philosophy emphasizing proportionality in compliance obligations. Rather than abandoning systemic risk monitoring or investor protection, the SEC and CFTC's proposal aims to eliminate data collection deemed unnecessary or redundant while preserving core information essential to regulatory oversight. This reflects a deliberate recalibration of the private fund regulatory regime following years of expanded disclosure requirements, signaling a regulatory environment more receptive to adviser concerns regarding administrative costs and operational efficiency.
The proposed amendments include several substantive modifications to the filing structure. The agencies propose raising the "large hedge fund adviser" threshold—which triggers quarterly filing obligations—from its current level of $1.5 billion in hedge fund assets under management. Additionally, the proposal would eliminate filing requirements for smaller advisers, a cohort representing approximately half of all currently registered advisers. Private equity quarterly reporting requirements would also be eliminated under the proposal, further streamlining disclosure obligations across the alternative fund industry.
Form PF serves dual regulatory purposes: it facilitates the Financial Stability Oversight Council's monitoring of systemic risk in financial markets and supports both the SEC and CFTC's investor protection efforts. The SEC and CFTC's coordinated approach, formalized through a March 11, 2026 memorandum of understanding establishing ongoing coordination frameworks, reflects institutional alignment on modernizing registration and reporting rules. CFTC Chairman Michael S. Selig emphasized that "by raising the filing threshold and streamlining Form PF, we are taking steps to reduce the burdens associated with filing the form," while noting the agencies would carefully review public comments during the rulemaking process.
The amendments are positioned within a broader regulatory philosophy emphasizing proportionality in compliance obligations. Rather than abandoning systemic risk monitoring or investor protection, the SEC and CFTC's proposal aims to eliminate data collection deemed unnecessary or redundant while preserving core information essential to regulatory oversight. This reflects a deliberate recalibration of the private fund regulatory regime following years of expanded disclosure requirements, signaling a regulatory environment more receptive to adviser concerns regarding administrative costs and operational efficiency.
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