Key Takeaways
- • The CFTC and SEC jointly proposed amendments to Form PF that would raise the filing threshold for all filers from $150 million to $1 billion in private fund assets under management, substantially reducing reporting obligations for smaller advisers.
- • The proposed amendments would eliminate filing requirements for approximately half of all advisers currently required to file Form PF, significantly reducing compliance burdens across the private fund industry.
- • The agencies aim to streamline Form PF reporting while maintaining systemic risk monitoring capabilities for the Financial Stability Oversight Council, eliminating certain quarterly event reporting requirements for private equity funds while preserving core disclosure obligations.
- • SEC Chairman Paul S. Atkins and CFTC Chairman Michael S. Selig framed the amendments as correcting overly burdensome disclosure requirements that distract advisers from core investment functions without proportionate regulatory benefit.
- • The proposal enters the public comment period, with both agencies indicating their intent to incorporate feedback before finalizing the amendments.
Summary
The Commodity Futures Trading Commission and Securities and Exchange Commission jointly proposed amendments to Form PF on April 20, 2026, marking a significant regulatory shift toward reducing private fund reporting obligations. The core proposal raises the filing threshold from $150 million to $1 billion in assets under management (AUM) for all filers, directly eliminating filing requirements for approximately half of the advisers currently required to submit Form PF reports.
Form PF serves as the confidential reporting mechanism for SEC-registered investment advisers managing private funds, including those also registered with the CFTC as commodity pool operators or commodity trading advisors. The form was designed to provide data to the Financial Stability Oversight Council for systemic risk monitoring in the private fund industry, while also supporting SEC and CFTC regulatory programs including examinations, investigations, and investor protection efforts.
The proposed amendments reflect a policy reorientation toward reducing unnecessary compliance costs. SEC Chairman Paul S. Atkins stated that prior Form PF amendments 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." CFTC Chairman Michael S. Selig added that the changes aim to "reduce the burdens associated with filing the form" while maintaining essential regulatory oversight. Both leaders emphasized the intent to bring the overall disclosure regime into alignment with its stated purpose.
The proposal streamlines disclosure obligations by eliminating certain quarterly event reporting requirements, particularly for private equity fund advisers, while preserving the form's systemic risk monitoring capabilities. The amendments now enter the public comment period, with both agencies indicating they will carefully review stakeholder feedback before finalizing the rule changes. This represents a notable departure from regulatory posture observed in prior Form PF amendments adopted in May 2023, which had introduced expanded current reporting for large hedge fund advisers.
Form PF serves as the confidential reporting mechanism for SEC-registered investment advisers managing private funds, including those also registered with the CFTC as commodity pool operators or commodity trading advisors. The form was designed to provide data to the Financial Stability Oversight Council for systemic risk monitoring in the private fund industry, while also supporting SEC and CFTC regulatory programs including examinations, investigations, and investor protection efforts.
The proposed amendments reflect a policy reorientation toward reducing unnecessary compliance costs. SEC Chairman Paul S. Atkins stated that prior Form PF amendments 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." CFTC Chairman Michael S. Selig added that the changes aim to "reduce the burdens associated with filing the form" while maintaining essential regulatory oversight. Both leaders emphasized the intent to bring the overall disclosure regime into alignment with its stated purpose.
The proposal streamlines disclosure obligations by eliminating certain quarterly event reporting requirements, particularly for private equity fund advisers, while preserving the form's systemic risk monitoring capabilities. The amendments now enter the public comment period, with both agencies indicating they will carefully review stakeholder feedback before finalizing the rule changes. This represents a notable departure from regulatory posture observed in prior Form PF amendments adopted in May 2023, which had introduced expanded current reporting for large hedge fund advisers.
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