SEC and CFTC Propose Form PF “Burden-Reduction” Amendments
Introduction
On April 20, 2026, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC,” and together with the SEC, the “Commissions”) jointly proposed amendments to Form PF, which is the confidential systemic‑risk reporting form for SEC‑registered investment advisers to private funds.[1] The proposal would recalibrate who must file Form PF, what must be reported, and how frequently, with the stated goal of reducing compliance burdens—especially for smaller advisers—while preserving the data necessary for systemic risk monitoring and investor protection. The proposal follows a multi-year sequence of Form PF amendments and delayed compliance dates for previously adopted reporting expansions (most recently extended to October 1, 2026).
The Commissions state that the amendments are designed to:
- Eliminate filing obligations for smaller private fund advisers;
- Eliminate certain reporting obligations for smaller hedge fund advisers;
- Remove or streamline a number of granular and event‑based reporting requirements adopted in 2023–2024 that have proved particularly burdensome;[2] and
- Make targeted corrections and clarifications to improve consistency and data quality.
Comments to the proposal are due 60 days after publication in the Federal Register. In addition, the Commissions are specifically requesting comments on whether to modify the information that advisers must report on Form PF about private credit funds.
Summary of Threshold Changes: Who Must File and Who is a “Large” Hedge Fund Adviser
A central feature of the proposal is recalibrating who is required to file Form PF at all, and who is treated as a “large hedge fund adviser” (and therefore subject to quarterly filing, Section 2 reporting for qualifying hedge funds and Section 5 current reporting). The proposal would significantly raise the baseline Form PF filing threshold for all Form PF filers and materially raise the bar for classification as a “large hedge fund adviser,” which drives more frequent and granular reporting.
Under the proposal, advisers below $1 billion in private fund assets under management (“AUM”) would no longer be required to file Form PF but would continue to report private fund information on Form ADV (i.e., Schedule D, Section 7.B.(1) Private Fund Reporting). Advisers with hedge fund assets between $1.5 billion and $10 billion would cease filing Sections 2 and 5 as large hedge fund advisers and would instead report annually in Section 1 (like smaller private fund advisers), in addition to continued Form ADV reporting.
|
Topic |
Current Requirement |
Proposed Requirement |
Stated Impact / Practical Effect |
|
Form PF filing threshold (all filers) |
File if adviser has ≥ $150 million in private fund AUM (as of fiscal year-end) |
Increase threshold to ≥ $1 billion in private fund AUM |
Expected to eliminate filing obligations for smaller advisers (almost half of current Form PF advisers), while retaining data on over 90% of private fund gross asset value reported |
|
Large hedge fund adviser threshold |
“Large” if ≥ $1.5 billion in hedge fund AUM (and advises at least one qualifying hedge fund), triggering quarterly filing and Sections 2 and 5 reporting |
Increase threshold to ≥ $10 billion in hedge fund AUM |
Expected to eliminate “large hedge fund adviser” reporting obligations for almost two‑thirds of current large hedge fund advisers, yet maintain quarterly coverage of over 80% of hedge fund gross asset value reported Many advisers would move from “large hedge” status to annual Section 1 filing only (and cease Sections 2 and 5 reporting obligations) |
Other Proposed Eliminations and Amendments Impacting all Form PF Filers: Section 1 and General Instructions
The proposal would remove or streamline several items that apply broadly to all filers, including changes to master-feeder and look-through mechanics.
|
Topic |
Current Framework |
Proposed Change |
|
Disregarded feeder funds (General Instruction 6) |
Filers must separately report each component fund of master-feeder arrangements and parallel fund structures, except under certain limited circumstances. |
Allow advisers to disregard a feeder fund if it invests no more than 5% of its gross asset value outside of (i) a single master fund; (ii) U.S. Treasury bills; and/or (iii) cash and cash equivalents |
|
“Look-through” mechanics for indirect exposures (General Instructions 7 and 8) |
Form PF provides instructions for where a filer should “look through” a reporting fund’s investments in other private funds and entities. |
Eliminate prescriptive look-through requirements for many indirect exposure calculations and instead allow reporting based on reasonable estimates consistent with internal methodologies and service-provider conventions (while retaining look-through to trading vehicles) |
|
Trading vehicles identification (Question 9) |
If a reporting fund holds assets, incurs leverage, or conducts trading or other activities through a trading vehicle, the adviser must provide identifying information about each such trading vehicle. |
Narrow the universe of trading vehicles for which identifying information must be provided. For example, advisers would be required to identify each trading vehicle that is listed or required to be listed in Section 7.B of Schedule D of Form ADV |
|
Performance volatility reporting (Question 23(c)) |
If an adviser calculates a market value on a daily basis for any position in the reporting fund’s portfolio, it must report certain volatility information including aggregated calculated values, monthly annualized volatility of returns, and other data associated with the daily rates-of-return. |
Eliminate volatility-related reporting tied to daily position valuation (including aggregated calculated values, monthly annualized volatility of returns, and related daily return-rate statistics) |
Proposed Amendments Affecting Large Hedge Fund Advisers (Sections 2 and 5)
In addition to shrinking the set of advisers that are “large hedge fund advisers,” the Commissions proposed to remove, streamline and/or simplify several questions introduced in or affected by the 2024 Amendments, thereby reducing the reporting burden for those large hedge fund advisers remaining in-scope.
Section 2 Reporting
|
Current Section 2 reporting item |
Proposed change |
|
Value of positions at end of reporting period for certain trading/clearing reporting (Questions 29 and 30) |
Eliminate requirement to report end-of-period (i.e., monthly) position values (while retaining other elements of the framework) |
|
Adjusted exposure reporting based on internal methodology (Question 32(b)(2)) |
Eliminate the “internal methodology” adjusted exposure reporting prong (while retaining other adjusted exposure reporting) |
|
Monthly asset turnover by asset class (Question 34) |
Eliminate monthly asset turnover reporting entirely |
|
Industry concentration reporting via six-digit NAICS codes (Question 36) |
Permit reporting with fewer digits of the NAICS codes (i.e., adding flexibility and reducing granularity burdens) |
|
Monthly netted/gross exposure to reference assets and concentrated exposure details (Questions 39 and 40) |
Eliminate these reference-asset exposure questions Add, in Section 5, Item B, an event‑based requirement for large hedge fund advisers to identify and describe the largest exposure contributing to a qualifying hedge fund’s extraordinary investment loss (≥ 20% loss over a rolling 10‑business‑day period), including dollar amount, sub‑asset class, instrument type, and issuer‑level identifiers (LEI, CUSIP, ISIN, ticker or other unique identifier). |
|
Consolidated counterparty exposure table (monthly, aggregated) (Question 41) |
Eliminate the consolidated counterparty exposure table and shift the framework to rely more heavily on other, more targeted reporting Qualifying hedge funds complete the consolidated counterparty exposure table in Question 26 (already required for other hedge funds), with monthly data, while detailed breakdowns by collateral type and expected collateral changes are removed |
|
Borrowing/counterparty reporting mechanics (Questions 18, 26, 42, 43, and related definitions) |
Conform and simplify the remaining counterparty reporting; require large hedge fund advisers to complete certain borrowing/creditor-type reporting for qualifying hedge funds in Question 18 (with conforming edits to other questions) |
|
Rehypothecation of collateral posted by counterparties (Question 45) |
Eliminate rehypothecation reporting due to data reliability and operational challenges |
Section 5 Current Reporting
Section 5 requires large hedge fund advisers to file current reports for specified events at their qualifying hedge funds.
|
Current Section 5 reporting feature |
Proposed change |
|
Filing deadline standard (Section 5, General Instruction) |
Replace “as soon as practicable, but no later than 72 hours” with a simpler “no later than 72 hours” standard |
|
Extraordinary investment loss reporting content (Section 5, Item B) |
Add a requirement to describe the largest exposure contributing to the loss (as a streamlined replacement for certain eliminated “reference asset” reporting) |
|
Margin default / inability to meet margin call trigger (Section 5, Item D) |
Eliminate Item D current reporting |
|
Operations events definition (Section 5, Item G) |
Narrow “operations event” by deleting the prong tied to disruption of operations necessary for compliance with federal securities laws and regulations (i.e., remove the second prong of “critical operations”) |
|
Inability to pay redemption requests (Section 5, Item I) |
Eliminate the prong tied to inability to pay redemption requests (while retaining the suspension-based trigger – i.e., if redemptions are suspended for more than five consecutive business days) |
Proposed Eliminations Affecting Private Equity Fund Advisers (Section 6 Quarterly Event Reporting)
The proposal would eliminate Form PF Section 6 in its entirety. Section 6 currently requires quarterly reporting (within 60 days of quarter-end) when certain private equity “events” occur, including adviser-led secondary transactions, general partner removals, termination of investment periods, and fund terminations. Under the proposal, those quarterly event reports would no longer be required.
Key Takeaways for Private Fund Managers
The proposal is directionally significant because it combines (i) an eligibility “gatekeeping” change that raises the overall filing threshold; (ii) targeted deletions of data elements that many advisers viewed as operationally complex, including look-through mechanics, volatility reporting tied to daily valuation, turnover metrics, certain reference-asset exposure reporting, and rehypothecation; and (iii) the removal of private equity quarterly event reporting.
If adopted substantially as proposed, the amendments would likely require many firms to reassess (a) whether they remain Form PF filers at all, (b) whether they remain “large hedge fund advisers,” and (c) whether existing buildouts for the previously adopted expansions remain necessary given the revised scope and eliminated questions.
Closing
This is the first of several proposals affecting investment advisers that we expect to see from the SEC in the coming months. Honigman will continue to monitor any further proposed rule amendments impacting investment advisers and private funds managers, including those related to Form PF and other reporting and regulatory requirements. Please do not hesitate to contact a member of our Investment Funds team with any questions about how these developments may affect your firm’s compliance program, examination readiness, or regulatory strategy.
[1] Form PF; Reporting Requirements for All Filers, Investment Advisers Act Release No. 6959 (Apr. 20, 2026), available at https://www.sec.gov/files/rules/proposed/2026/ia-6959.pdf (the “Proposed Rule”)
[2] See Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers, 89 Fed. Reg. 17984 (March 12, 2024), available at: https://www.govinfo.gov/content/pkg/FR-2024-03-12/pdf/2024-03473.pdf (the “2024 Amendments”); and Form PF; Event Reporting for Large Hedge Fund Advisers and Private Equity Fund Advisers; Requirements for Large Private Equity Fund Adviser Reporting, 88 Fed. Reg. 38146 (June 12, 2023), available at: https://www.govinfo.gov/content/pkg/FR-2023-06-12/pdf/2023-09775.pdf (the “2023 Amendments”)
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