U.S. SEC and CFTC Propose Changes to Reduce Form PF Reporting Obligations

On April 20, 2026, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC, and together with the SEC, the Commissions) jointly proposed amendments to Form PF, the confidential reporting form filed by certain SEC-registered investment advisers to private funds, including certain advisers that are also registered with the CFTC as commodity pool operators or commodity trading advisors (the Proposal).

The Proposal is the Commissions’ latest step in the ongoing reconsideration of Form PF, which was adopted in 2011 and amended in 2014, 2023, and 2024. In 2024, the Commissions adopted broad amendments to Form PF (the 2024 Amendments), but the compliance date for those amendments has been delayed several times. As a result, advisers have continued to file the version of Form PF that was in effect before the 2024 Amendments. The Proposal would revise that course by increasing key reporting thresholds, eliminating certain existing reporting obligations and new reporting obligations created by the 2024 Amendments, and narrowing or simplifying several reporting requirements that otherwise would have taken effect as part of the delayed 2024 Amendments.

The Proposal was published in the Federal Register on April 24, 2026. Comments are due on June 23, 2026. If adopted as proposed, the 2024 Amendments would have a minimum 12-month transition period from the date of publication in the Federal Register, with certain filers having additional time depending on their reporting cycle.

Overview of the Proposal

The Proposal is designed to reduce Form PF reporting burdens while preserving the Commissions’ and the Financial Stability Oversight Council’s ability to monitor systemic risk. The most significant proposed changes are as follows:

Requirement / Category	Existing Form PF Threshold	April 2026 Proposed Form PF Threshold
General Form PF filing threshold	SEC-registered adviser with ≥ $150 million in private fund assets under management (AUM)	≥ $1 billion in private fund AUM
Large hedge fund adviser	≥ $1.5 billion in hedge fund AUM	≥ $10 billion in hedge fund AUM
Qualifying hedge fund	Hedge fund with ≥ $500 million net asset value (NAV)	No threshold change identified
Large liquidity fund adviser	Advises liquidity fund(s) and has ≥ $1 billion combined liquidity fund and money market fund AUM	No change
Large private equity fund adviser	≥ $2 billion in private equity fund AUM	No change
Private equity quarterly event reporting / Section 6	Applies to advisers to private equity funds for specified private equity reporting events	Eliminated
Large hedge fund current reporting / Section 5	Large hedge fund advisers report specified events for qualifying hedge funds within 72 hours / as soon as practicable	Report within 72 hours, but only for advisers meeting the proposed $10 billion large hedge fund adviser threshold; certain triggers narrowed

Please see the table at the end of this Update for a high-level summary of the proposed changes as compared with the existing Form PF.

Our Take

• The Proposal represents a meaningful recalibration of Form PF and a notable shift away from the more expansive reporting approach reflected in the 2024 Amendments. Advisers below the proposed thresholds could see significant relief: The Commissions estimate that raising the general filing threshold to $1 billion would eliminate Form PF filing obligations for approximately 43% of private fund advisers that currently file Form PF.
• While the Commissions ’ estimate that raising the large hedge fund adviser threshold to $10 billion would eliminate certain reporting obligations for almost two-thirds of current large hedge fund adviser filers, the Proposal does not address the broad definition of “hedge fund” itself, meaning advisers operating strategies that happen to satisfy the definition will continue completing data fields designed to capture risks they do not actually pose. Advisers in this position should consider whether the comment process presents a narrow window to advocate for a more tailored definition, particularly given that more precise reporting could better serve the Commissions’ objective  of utilizing Form PF for systemic risk monitoring.
• The Proposal is not, however, a full retreat from Form PF expansion. Compared with the current operative Form PF, it would still introduce technical changes to fund structure reporting, indirect exposure reporting, trading vehicle identification, trading and clearing reporting, counterparty exposure reporting, and targeted current reporting. Advisers with complex master-feeder structures, fund-of-funds exposures, trading vehicles, or complex financing arrangements may still need to build or refine reporting processes.
• Fund-of-funds and other advisers that invest through private funds should distinguish carefully between the Proposal’s relaxed approach to certain indirect exposure reporting and the separate threshold calculations that determine Form PF filing status. The Proposal would permit reasonable estimates for certain indirect exposure questions, but it would not allow advisers to reduce counted assets for purposes of the proposed $1 billion general filing threshold, the proposed $10 billion large hedge fund adviser threshold, or other Form PF thresholds. In addition, mandatory look-through reporting would remain for trading vehicle holdings.
• The request for comment on private credit is particularly important. The Proposal does not create a private credit section, but the Commissions’ questions suggest that dedicated private credit reporting remains under consideration. Private credit advisers should consider using the comment process to address how existing Form PF categories fit private credit strategies and to identify burdens, data limitations, and definitional issues that could arise from any new private credit reporting regime.
• Advisers should also consider collateral consequences. For example, CFTC no-action relief under CFTC No-Action Letter No. 25-50 for certain SEC-registered private fund managers operating pools offered solely to qualified eligible persons is conditioned, among other things, on the relevant pool being reported on Form PF. If the general Form PF filing threshold is raised to $1 billion, managers that fall below the new threshold may need to evaluate whether they can continue to satisfy that condition, whether voluntary filing of Form PF would be available, and whether the CFTC should clarify the interaction between the Form PF threshold and the no-action relief. The CFTC has stated that it intends to codify Letter No. 25-50. It is important that the CFTC address this issue in the rulemaking process in a manner that is coordinated with the Commissions’ amendments to Form PF.
• Until final rules are adopted, advisers should prepare for multiple outcomes. In particular, advisers should assess whether they would fall below the proposed $1 billion or $10 billion thresholds, identify which Form PF data collection processes would become unnecessary, and evaluate where the Proposal would require new or different reporting relative to current Form PF. Advisers considering comments may want to focus on threshold calibration, fund structure reporting, indirect exposures, trading vehicle reporting, counterparty netting and cross-margining, private credit, and the interaction between Form PF filing status and other regulatory regimes.
• The interaction between the Proposal’s transition timeline and the delayed 2024 Amendments raises questions about timing creating interim uncertainty for advisers’ data collection processes, reporting infrastructure, and compliance controls in preparation for future Form PF filings. We suspect that the Commissions will address these timing and implementation issues in connection with any final rulemaking process, including through guidance or FAQs, as they have done in connection with the 2024 Amendments and related compliance date.

Key Open Questions for Private Fund Managers

The Proposal includes 134 requests for comment. Several are particularly important for private fund advisers and may warrant consideration in comment letters.

Threshold calibration. The Commissions request comment on whether the proposed $1 billion general filing threshold and $10 billion large hedge fund adviser threshold are appropriate, whether alternative thresholds should be adopted, and whether thresholds should be adjusted for inflation or reviewed periodically. The Commissions also ask whether any of the qualifying hedge fund threshold, large liquidity fund adviser threshold, or large private equity fund adviser threshold should be increased.

Master-feeder and parallel fund reporting. The Proposal would move current practice toward separate reporting of component funds, subject to the disregarded feeder fund exception. Advisers should consider whether the proposed 5% gross asset value threshold for disregarded feeder funds is appropriate, whether advisers should be able to aggregate feeders that are not separately considered for risk management purposes, and whether gross asset value is the right denominator.

Indirect exposures and fund-of-funds investments. The Proposal would permit reasonable estimates for required indirect exposures, but the Commissions request comment on whether look-through reporting should be eliminated entirely or retained only for certain questions, fund types, entities, or reference assets. Fund-of-funds managers and managers with allocations to external private funds may want to focus on data access, timing mismatches, service provider limitations, and whether reporting should align more closely with internal risk management.

Trading vehicles and passive structures. The Proposal narrows the universe of trading vehicles that must be identified, but it still asks whether the identification of trading vehicles is relevant to systemic risk assessment. Managers that use tax blockers, liability blockers, aggregators, holding companies, or other nonoperating vehicles should consider whether additional clarification is needed to avoid over-reporting passive entities.

Counterparty exposure, netting, and cross-margining. The Commissions ask detailed questions about whether counterparty exposure should be reported on a net or a gross basis, whether advisers should be permitted to use internal methodologies for netting and cross-margining, how collateral should be classified, and whether significant counterparty reporting should capture all borrowings or only cash borrowings. These questions are likely to be particularly important for advisers using prime brokerage, repo, derivatives, cross-margining, or other financing arrangements.

Current reporting. The SEC asks whether the 72-hour deadline is too short or too long, whether it should be expressed in business days, whether Section 5’s margin default and inability-to-meet-margin-call reporting item should be eliminated or revised with a materiality threshold, whether the operations event trigger should be eliminated entirely, and whether the redemption-related reporting item should be further modified or eliminated. Large hedge fund advisers that have built escalation procedures around current reporting should consider whether the Proposal would resolve the interpretive issues that they have encountered.

Private equity event reporting. The SEC asks whether Section 6 should be eliminated entirely or whether some events, such as general partner removals, should instead be reported annually or in Section 1 of Form PF. Private equity advisers may want to address the operational costs of quarterly event reporting and the extent to which reported events are idiosyncratic rather than useful indicators of broader market stress.

Private credit. The Commissions ask whether Form PF should include a new private credit section or subsection, how “private credit” and “private credit fund” should be defined, what reporting threshold should apply, and what data should be collected regarding strategy, leverage, financing counterparties, maturity, investor liquidity, liquidity management, credit quality, and loan exposures. Advisers with private credit strategies should consider whether current Form PF categories adequately capture their funds or whether any private credit reporting should be narrowly tailored.

Transition timing. The Commissions propose a minimum 12-month transition period from Federal Register publication but ask whether the transition should be shorter or longer and whether threshold changes should become effective sooner than other amendments. This is important because the delayed 2024 Amendments currently have an October 1, 2026 compliance date.

Summary of Key Proposed Changes Compared With Current Form PF

The table below provides a high-level summary of the proposed changes as compared with the existing Form PF.

Requirement / Category	Existing Form PF	Proposed Change	Practical Impact
General Form PF filing threshold	SEC-registered advisers file Form PF if they and their related persons collectively have at least $150 million in private fund AUM as of the last day of the adviser’s most recently completed fiscal year.	Increase the filing threshold to $1 billion in private fund AUM.	Many midsize private fund advisers would no longer file Form PF at all, although they would still be required to report private fund information on Form ADV.
Large hedge fund adviser threshold	A Form PF filer and its related persons are large hedge fund advisers if they have at least $1.5 billion in hedge fund AUM and advise at least one qualifying hedge fund. Large hedge fund advisers file Form PF quarterly, complete Section 2 reporting for qualifying hedge funds, and are subject to Section 5 current reporting for certain significant events.	Increase the large hedge fund adviser threshold to $10 billion in hedge fund AUM.	Many hedge fund advisers that currently file quarterly and complete Section 2 reporting for qualifying hedge funds would instead file annually and would not be subject to Section 5 current reporting for significant events, absent another quarterly filing obligation.
Periodic threshold review	No specific periodic review requirement for Form PF thresholds.	Require SEC staff to report to the SEC on each filing and reporting threshold approximately five years after the compliance date and approximately every five years thereafter.	The Proposal would build a recurring threshold review mechanism into the rule rather than relying on ad hoc recalibration.
Master-feeder arrangements and parallel fund structures	Current Form PF generally permits advisers to report master-feeder arrangements and parallel fund structures either in the aggregate or separately, provided the approach is applied consistently.	Generally require separate reporting for component funds but permit a feeder fund to be treated as disregarded if investments outside a single master fund, U.S. Treasury bills, and cash and cash equivalents do not exceed 5% of the feeder fund’s gross asset value.	Although the 5% exception is a helpful accommodation, the Proposal would still be a meaningful change for advisers that currently aggregate master-feeder or parallel fund structures rather than preparing separate fund-level reports.
Indirect exposures and look-through reporting	Current Form PF generally does not impose a broad mandatory look-through requirement for investments in other funds or entities unless a question specifically requires it.	Permit advisers to report required indirect exposures based on reasonable estimates consistent with internal methodologies and service provider conventions for specified questions. Mandatory look-through would remain for trading vehicle holdings.	This is more flexible than the 2024 Amendments, but it may still require advisers to develop more consistent processes for reporting indirect exposures as compared to current Form PF.
Trading vehicle identification	Current Form PF does not require advisers to identify each trading vehicle used by a reporting fund.	Require identification of trading vehicles only if they are listed or required to be listed on Form ADV Schedule D, Section 7.B., or are included or required to be included in responses to specified counterparty or creditor exposure questions.	Advisers would need to inventory relevant trading vehicles, but the Proposal narrows the scope to vehicles viewed as more relevant to counterparty, credit, or private fund reporting. Passive blockers and holding vehicles generally should receive less attention unless they are required to be identified on Form ADV Schedule D or in specified counterparty or creditor exposure responses.
Trading and clearing information	Current Form PF requires certain percentage-based information regarding how hedge funds trade securities and derivatives.	Require reporting of the value traded for certain instruments and trading modes while not implementing the separate end-of-period position value reporting that had been included in the 2024 Amendments. The Proposal also would correct certain value-traded instructions.	Advisers to hedge funds would still face a revised trading and clearing reporting framework, but the Proposal removes one of the more burdensome duplicative data points.
Performance volatility reporting	Current Form PF does not require the daily calculated value and monthly annualized volatility reporting that had been included in the 2024 Amendments.	Do not implement the delayed performance volatility reporting requirement that would have required certain daily calculated value and monthly annualized volatility information.	No incremental performance volatility reporting obligation would be added for this item.
Adjusted exposure reporting	Current Form PF requires large hedge fund advisers to report certain exposure information for qualifying hedge funds but does not include all of the adjusted exposure mechanics adopted in the 2024 Amendments.	Retain prescribed adjusted exposure reporting but eliminate the requirement to report adjusted exposure a second time using the adviser’s internal methodology.	Large hedge fund advisers would avoid duplicative adjusted exposure reporting, although the Proposal would still require careful attention to prescribed netting and exposure methodologies.
Monthly asset turnover	Large hedge fund advisers currently report monthly turnover information by asset class for qualifying hedge funds.	Eliminate monthly asset turnover reporting.	This would remove a data point that the Commissions now describe both as an imprecise signal of systemic risk or market turmoil and as operationally burdensome for high-volume trading strategies.
Industry concentration reporting	Current Form PF does not require the six-digit North American Industry Classification System (NAICS) code industry exposure reporting framework included in the 2024 Amendments.	Permit reporting at any level of NAICS code classification rather than requiring six-digit NAICS codes.	The Proposal would still move toward industry exposure reporting for qualifying hedge funds but with more flexibility than the 2024 Amendments.
Reference asset exposure reporting	Current Form PF does not require the detailed reference asset reporting reflected in Questions 39 and 40 of the 2024 Amendments.	Do not implement the detailed monthly reference asset exposure reporting adopted in the 2024 Amendments. Instead, require, in an extraordinary investment loss current report, a description of the largest exposure contributing to the loss, including dollar amount and identifying information.	The Proposal would avoid the most granular monthly reference asset reporting but would add targeted exposure information applicable when a qualifying hedge fund experiences an extraordinary investment loss.
Counterparty exposure reporting	Current Form PF includes counterparty and creditor exposure reporting for hedge funds and qualifying hedge funds, including significant counterparty information and rehypothecation reporting.	Simplify large hedge fund adviser counterparty exposure reporting by eliminating the more granular consolidated counterparty exposure table that had been included in the 2024 Amendments. Qualifying hedge funds would complete a simpler consolidated counterparty exposure table, and significant counterparty borrowing reporting would be revised to include all borrowings, not only cash borrowings.	The Proposal would reduce some of the most operationally difficult counterparty reporting, but advisers should still expect meaningful changes to significant counterparty, borrowing, collateral, netting, and cross-margining reporting.
Rehypothecation reporting	Large hedge fund advisers currently report the percentage of collateral posted by counterparties to a qualifying hedge fund that may be and has been rehypothecated.	Eliminate rehypothecation reporting.	This would eliminate a reporting item that the Commissions describe as difficult to collect reliably and operationally challenging.
Large hedge fund current reporting deadline	Section 5 current reports are due as soon as practicable, but no later than 72 hours, after a reportable event.	Remove the as-soon-as-practicable standard and retain a 72-hour deadline.	Large hedge fund advisers would have a clearer filing deadline and reduced need to make a separate judgment regarding whether an earlier filing is practicable.
Current reporting for margin default or inability to meet margin, collateral, or equivalent call	Section 5 currently requires large hedge fund advisers to file a current report if a qualifying hedge fund experiences a margin default or the adviser determines that the fund cannot meet a call for margin, collateral, or equivalents.	Eliminate this margin default and inability-to-meet-margin-call reporting item.	The SEC indicates that material margin stress may be captured through other current reporting triggers, including extraordinary investment losses and significant margin increases.
Operations events	Section 5 currently requires large hedge fund advisers to file a current report for significant disruption or degradation of a qualifying hedge fund’s critical operations, including operations necessary for investment, trading, valuation, reporting, and risk management, as well as operations necessary for the fund to operate in accordance with federal securities laws and regulations.	Narrow the operations event trigger by eliminating the prong relating to operation in accordance with federal securities laws and regulations, while retaining current reporting for significant disruption or degradation of specified operational functions.	This would narrow a trigger that has raised interpretive questions and reduce the monitoring burden for large hedge fund advisers.
Inability to satisfy redemption requests	Section 5 currently requires large hedge fund advisers to file a current report if a qualifying hedge fund is unable to pay redemption requests or has suspended redemptions for more than five consecutive business days.	Eliminate the trigger for inability to pay redemption requests, while retaining current reporting for redemption suspensions lasting more than five consecutive business days.	The Proposal would reduce ambiguity around in-kind redemptions and other circumstances where a redemption is not paid in cash but may not reflect liquidity stress.
Private equity quarterly event reporting	Section 6 currently requires large private equity fund advisers to file quarterly reports for adviser-led secondary transactions, general partner removals, investment period terminations, and fund terminations.	Eliminate Section 6 private equity quarterly event reporting in its entirety.	Large private equity fund advisers would no longer file quarterly reports for adviser-led secondary transactions, general partner removals, investment period terminations, or fund terminations. The Proposal reflects the SEC’s view that these reports have been less useful for investor protection and systemic risk monitoring than expected.
Private credit reporting	Form PF does not define “private credit” or “private credit fund,” and private credit is listed as a strategy option rather than a separate reporting regime.	No specific private credit reporting amendments are proposed, but the Commissions request comment on whether to add a new private credit section or subsection, what data should be collected, and what threshold should apply.	Private credit advisers should treat the request for comment as an early indicator that targeted private credit reporting may remain on the regulatory agenda.

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