Key Takeaways
- • The SEC and CFTC jointly proposed on April 20, 2026, amendments to Form PF that raise the AUM reporting threshold from $150 million to $1 billion, eliminating filing obligations entirely for smaller advisers representing nearly half of current filers.
- • The proposal eliminates quarterly reporting requirements for private equity advisers and streamlines periodic and current reporting obligations for large hedge fund advisers, significantly reducing compliance burdens across the private fund industry.
- • The amendments stem from a regulatory review process initiated by a presidential memorandum in January 2025 directing agencies to reconsider the effective date and policy implications of rules not yet in effect, including the 2024 Form PF amendments originally scheduled for March 2025 compliance.
- • The public comment period extends 60 days from Federal Register publication, allowing stakeholders to provide feedback before potential adoption by the agencies.
- • The proposal maintains Form PF's core function of collecting systemic risk information while reducing reporting complexity through threshold increases and elimination of multiple reporting categories.
Summary
On April 20, 2026, the Securities and Exchange Commission and Commodity Futures Trading Commission jointly proposed comprehensive amendments to Form PF, the confidential reporting requirement for SEC-registered investment advisers to private funds and CFTC-registered commodity pool operators and commodity trading advisers. The proposal represents a substantial revision to regulatory expectations established by 2024 amendments that were originally scheduled for compliance in March 2025.
The most significant change raises the AUM threshold triggering any Form PF filing obligations from $150 million to $1 billion. This modification eliminates reporting requirements entirely for smaller advisers, which currently constitute approximately half of all Form PF filers. For advisers that remain subject to filing, the proposal streamlines both periodic and current reporting obligations, with particular relief for large hedge fund advisers. Notably, the amendments eliminate quarterly reporting requirements for private equity advisers, reducing filing frequency and associated compliance costs.
The proposed amendments reflect a policy recalibration initiated by a presidential memorandum issued in January 2025 that directed federal agencies to review postponement of rules not yet effective and to re-examine underlying questions of fact, law, and policy. This directive led the SEC and CFTC to reconsider the 2024 Form PF amendments before their March 2025 effective date, resulting in the current proposal to scale back and streamline reporting requirements.
According to the agencies' stated rationale, the amendments are designed to reduce regulatory reporting burdens while preserving Form PF's ability to collect information necessary for monitoring systemic risk in the private fund industry. The proposal eliminates multiple categories of reporting previously required under the 2024 amendments while maintaining disclosure of material information from advisers managing substantial assets.
The agencies have established a 60-day public comment period following Federal Register publication for the proposal, allowing market participants, compliance professionals, and other stakeholders to submit feedback before potential final adoption.
The most significant change raises the AUM threshold triggering any Form PF filing obligations from $150 million to $1 billion. This modification eliminates reporting requirements entirely for smaller advisers, which currently constitute approximately half of all Form PF filers. For advisers that remain subject to filing, the proposal streamlines both periodic and current reporting obligations, with particular relief for large hedge fund advisers. Notably, the amendments eliminate quarterly reporting requirements for private equity advisers, reducing filing frequency and associated compliance costs.
The proposed amendments reflect a policy recalibration initiated by a presidential memorandum issued in January 2025 that directed federal agencies to review postponement of rules not yet effective and to re-examine underlying questions of fact, law, and policy. This directive led the SEC and CFTC to reconsider the 2024 Form PF amendments before their March 2025 effective date, resulting in the current proposal to scale back and streamline reporting requirements.
According to the agencies' stated rationale, the amendments are designed to reduce regulatory reporting burdens while preserving Form PF's ability to collect information necessary for monitoring systemic risk in the private fund industry. The proposal eliminates multiple categories of reporting previously required under the 2024 amendments while maintaining disclosure of material information from advisers managing substantial assets.
The agencies have established a 60-day public comment period following Federal Register publication for the proposal, allowing market participants, compliance professionals, and other stakeholders to submit feedback before potential final adoption.
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