On 20 April 2026, the SEC and CFTC proposed amendments to Form PF aimed at reducing reporting burdens while preserving data for systemic risk oversight.
Key elements of the proposal include raising the Form PF filing threshold from $150 million to $1 billion in private fund assets under management, which would eliminate filing obligations for many smaller advisers. The proposal also raises the large hedge fund adviser threshold from $1.5 billion to $10 billion, reducing quarterly and current-reporting obligations for many advisers that currently report as “large”.
Additional streamlining includes easing certain master-feeder reporting (a 5% de minimis feeder concept), replacing prescriptive “look through” requirements with reasonable estimates, and eliminating select volatility, turnover, rehypothecation, and other data points viewed as costly to produce.
If adopted, these changes could materially reduce compliance time and systems buildouts for Form PF filers.
Comments are due 60 days after Federal Register publication.
For full press release click here.
For guidance on how these proposed changes may affect your Form PF obligations or broader regulatory strategy, please reach out to us and we’d be pleased to assist.
