SEC Proposes Major Rollback of Form PF Requirements
On April 20, 2026, the SEC and CFTC proposed sweeping changes to Form PF reporting. If adopted, these changes would significantly reduce Form PF private fund reporting requirements.
While regulators would not abandon Form PF entirely, the proposed amendments would significantly reduce the scope and complexity of required reporting.
Reduction in number of Form PF filers: In particular, the proposed amendments would raise the Form PF filing threshold for all filers, from $150 million in private fund assets under management to $1 billion. This change is designed to eliminate filing obligations for many advisers that currently must file Form PF, while continuing to obtain information on a significant percentage of private fund gross asset value that advisers report.
Fewer quarterly Form PF filers: Further, the proposed amendments would also raise the reporting threshold for large hedge fund advisers from $1.5 billion in hedge fund assets under management to $10 billion. This change is designed to eliminate certain reporting obligations for many advisers that currently must report quarterly as large hedge fund advisers, while continuing to obtain information quarterly from a substantial portion of hedge fund gross asset value that advisers report.
Streamlined Reporting: In addition to amending these thresholds, the proposal also would streamline many Form PF requirements including:
- eliminating certain “look through” requirements;
- eliminating certain performance volatility reporting requirements;
- simplifying certain large hedge fund counterparty exposure reporting;
- eliminating certain current reporting for large hedge fund advisers in Section 5 of Form PF;
- eliminating quarterly event reporting for all private equity fund advisers in Section 6 of Form PF; and
- making corrections and other revisions.
Background
Form PF was originally introduced in the wake of the 2008 financial crisis to provide regulators with greater visibility into systemic risk across the private fund industry. The Form was officially adopted in 2011. The Form provides the SEC and CFTC as well as the Financial Stability Oversight Council (FSOC) with confidential information about the operations and strategies of private funds and their advisers.
The Form requires private fund advisers to confidentially report portfolio investment exposures and risk information about the private funds that they advise.
Over time, the Form expanded significantly, requiring more granular, frequent, and operationally intensive disclosures through various amendments adopted by the SEC.
In particular, under the stewardship of former SEC Chair Gary Gensler from 2021 to2025, the SEC adopted amendments to Form PF in 2023 and 2024 that many filers described as overly complex.
However, new SEC Chair Paul Atkins, who was officially sworn in to this role in April 2025, stated in June 2025 that he had “serious concerns” about whether the burdens imposed on private fund advisers by the new Form PF amendments were justified by their utility to regulators.
In announcing these proposed amendments, he stated that “Prior amendments to Form PF have led to 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. These proposed changes would help to rationalize the scope of Form PF requirements to support its purpose and bring our overall disclosure regime back into alignment.”
Specifics of the Amendments: Who Would File When?
Under the amendments, the baseline threshold for Form PF filing would jump from $150 million to $1 billion in private fund AUM. For many smaller advisers, that change alone would eliminate the obligation to file altogether.
The shift would be even more pronounced for hedge fund managers. The “large hedge fund adviser” threshold would increase from $1.5 billion to $10 billion, meaning a substantial number of mid-sized managers would no longer be subject to the more intensive quarterly reporting regime.
A Meaningful Reduction in Reporting Complexity
Beyond thresholds, the proposal would address one of the private fund industry’s biggest gripes with the Form: complexity.
Over the past several years, Form PF has evolved into a highly detailed reporting exercise, particularly for firms with multi-layered fund structures. The proposed amendments would roll back many of these requirements.
Among the most notable changes:
- Elimination of certain performance and volatility metrics
- Reduced counterparty and exposure reporting
- Removal of portfolio turnover and trading detail disclosures
- Scaling back of rehypothecation and clearing data requirements
Perhaps most welcome for many firms is the simplification of fund structure reporting. The proposal removes several look-through requirements and reduces the need to separately report certain feeder fund arrangements.
Reduction of Event Reporting Obligation
Another major feature of the 2024 amendments was the introduction of near real-time reporting for certain events ranging from margin stress to redemption issues, culminating in the adoption of Section 5.
The new proposal reverses course on many of these requirements.
Several event-based triggers would be eliminated or scaled back, including reporting related to:
- Certain margin and default events
- Operational disruptions
- Redemption constraints
Further, private equity advisers would see relief with the removal of quarterly event reporting requirements in Section 6.
Transition Period
Interested parties may submit a comment letter on the proposed amendments through June 23, 2026.
The SEC and CFTC also proposed providing a minimum 12-month transition period from the date the amendments are officially adopted.
The SEC and CFTC are mindful that the compliance date for the originally adopted 2024 amendments is October 1, 2026, and the commissions will consider how the timing of any amendments that the commissions may adopt will relate to that timing.