Overview
On April 20, 2026, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly proposed amendments to Form PF (the Proposing Release)[1] that are intended to streamline reporting requirements so private fund advisers can provide useful data that is not duplicative nor unnecessarily burdensome. In this article, we provide both a summary and a chart outlining certain important proposed changes in the Proposing Release.
In Depth
Reduced reporting burdens on smaller managers:
- Increases the filing threshold from $150 million to $1 billion in private fund assets under management, which is expected to reduce the number of filers by approximately 43% while reducing the assets covered by the filings by only 2%
- Increases the reporting threshold for “large hedge fund advisers” from $1.5 billion to $10 billion, which is expected to reduce the number of advisers reporting in Section 2 of Form PF by approximately 65% while reducing the assets covered by such filings by only 10%
Reduced new reporting requirements of feeder funds and trading vehicles, which would otherwise have taken effect in October 2026:
- Eliminates the requirement to separately report most feeder funds in a master-feeder structure, reducing duplicative filings and better aligning the reporting with Form ADV
- Eliminates the requirement to separately report passive vehicles, reducing duplicative filings and allowing the SEC to focus on trading vehicles that are more relevant to its risk assessment
Elimination of burdensome and redundant reporting requirements:
- Eliminates duplicative reporting of information that is captured elsewhere in Form PF, including certain information with respect to volatility reporting, portfolio turnover reporting, rehypothecated reporting, certain adjusted exposure reporting, and certain reference asset exposure reporting
Elimination of certain “event” reporting:
- Eliminates the requirement for private equity fund advisers to file quarterly reports that do not provide impactful data
- Eliminates the requirement that current reports must be filed “as soon as practicable, but no later than 72 hours” and instead requires them to be filed within 72 hours
- Eliminates the requirement to file a current report for events that would be addressed by other questions in Form PF such as margin defaults or the inability to pay redemption requests
Specific reporting requirements for private credit funds:
- Requests comments on the incorporation of private credit fund-specific reporting into Form PF, providing an opportunity for input with respect to private credit funds
Connection to CFTC Letter No. 25-50 no-action relief
Many registered Commodity Pool Operators (CPOs) have been evaluating whether to rely on the CFTC’s CPO relief in Letter No. 25-50 (issued in December 2025). Similar to former Rule 4.13(a)(4), the relief is available to registered investment advisers to certain private funds limited to qualified purchasers (provided that Form PF is filed for the fund). Managers with regulatory assets under management below $1 billion who are currently registered CPOs and considering deregistration should therefore weigh the potential trade-off created by the proposed Form PF amendments: Deregistering could mean voluntarily continuing to file Form PF to preserve reliance on Letter No. 25-50 relief.
Transition period for the final rule
The Proposing Release includes a minimum 12-month transition period from the date of publication of the final rule in the Federal Register. The SEC also acknowledged the October 1, 2026, compliance date for the version of Form PF adopted in 2024 and stated that it will consider how the timing of any amendments they may adopt will relate to that date. We expect the final rule to be adopted prior to October 1, making the new reporting requirements effective on that date moot.
Key changes to Form PF
The chart below outlines the proposed key changes to Form PF from the Proposing Release. We compare these proposed key changes with current Form PF reporting requirements and the 2024 amendments to Form PF that are not yet in effect.
| Current requirements* | 2024 amendments adopted but not yet in effect** | Proposed 2026 amendments | |
|---|---|---|---|
| Filing threshold | Private fund advisers with at least $150 million in private fund assets under management (AUM). | Private fund advisers with at least $150 million in private fund AUM. | Private fund advisers with at least $1 billion in private fund AUM. |
| Large hedge fund adviser threshold | Private fund advisers with at least $1.5 billion in hedge fund AUM. | Private fund advisers with at least $1.5 billion in hedge fund AUM. | Private fund advisers with at least $10 billion in hedge fund AUM. |
| Master-feeder and parallel fund reporting | Private fund advisers may choose to report master-feeder arrangements and parallel fund structures on an aggregated or separated basis, so long as they do so consistently throughout Form PF. | Private fund advisers must separately report each feeder fund in a master-feeder arrangement unless the feeder fund invests all of its assets in a single master fund, in US treasury bills, and/or in cash and cash equivalents. Private fund advisers must separately report each component fund in a parallel fund structure. | Private fund advisers are not required to separately report feeder funds unless they hold 5% or more of their gross asset value outside of a single master fund, US treasury bills, and/or cash equivalents. Private fund advisers must separately report each component fund in a parallel fund structure. |
| Look-through requirement for investments in other private funds | Generally, private fund advisers may, but are not required to, “look through” a reporting fund’s investments in other private funds and entities. | Under certain specific circumstances, private fund advisers are required to “look through” a reporting fund’s investments in other private funds and entities. | Private fund advisers are not required to “look through” a reporting fund’s investments in other private funds and entities. Private fund advisers may instead report indirect exposures based on reasonable estimates that are consistent with their internal methodologies and the conventions of service providers. |
| Identification of trading vehicles | No requirement. | Private fund advisers are required to identify trading vehicles when a reporting fund holds assets, incurs leverage, or conducts trading or other activities through the trading vehicle. | Private fund advisers are required to identify trading vehicles under a narrower set of circumstances, including when they are disclosed in Section 7.B. of Schedule D of Form ADV or when referenced in response to certain questions on Form PF. |
| Volatility reporting requirements | No requirement. | Question 23(c) requires private fund advisers to report certain volatility information if the adviser calculated a market value on a daily basis for any position in the reporting fund’s portfolio. | No requirement. |
| Trading and clearing reporting requirements | Private fund advisers are required to report certain information on their use of trading and clearing mechanisms in response to Question 24, including the estimated percentage of securities and derivatives that were traded by each reporting fund on a regulated exchange and over the counter; the estimated percentage of derivatives that were traded by each reporting fund and cleared by a central counterparty clearing house (CCP) or bilaterally transacted; and the estimate percentage of repo trades that were entered into by each reporting fund and cleared by a CCP, bilaterally transacted, and constitute a tri-party repo. | Question 29 requires private fund advisers to report the value traded and end-of-reporting-period value for different asset classes based on how they were traded. Question 30 requires private fund advisers to report the value traded and the end-of-reporting-period value for any asset class not covered by Question 29. | Question 29 requires private fund advisers to report the value traded for different asset classes based on how they were traded. Question 30 requires private fund advisers to report the value traded for any asset class not covered by Question 29. The requirement to report the end-of-reporting-period value in response to Questions 29 and 30 is eliminated. |
| Adjusted exposure reporting | No requirement. | Question 32(b)(1) requires large hedge fund advisers to calculate and report adjusted exposure of long and short positions for each sub-asset class by netting positions that have the same underlying reference asset across instrument type and, for fixed income positions, within the same term using different maturity buckets. Question 32(b)(2) requires reporting adjusted exposure of long and short positions for each sub-asset class in which each qualifying hedge fund has a reportable position. | Question 32(b)(1) requires large hedge fund advisers to calculate and report adjusted exposure of long and short positions for each sub-asset class by netting positions that have the same underlying reference asset across instrument type and, for fixed income positions, within the same term using different maturity buckets. Furthermore, the term “counterparties” is removed from the last sentence of Question 32(b)(1), which previously stated that the reporting fund may net counterparties consistent with the information it reports internally and to current and prospective investors. Based on discussions the SEC has had with Form PF filers, the SEC believes that the inclusion of “counterparties” in this sentence has created confusion because netting in this section is intended to be associated with exposures rather than limiting netting specifically to counterparties. Question 32(b)(2) is removed from Form PF. |
| Portfolio turnover reporting | Private fund advisers are required to report the value of turnover during the month in certain asset classes. | Private fund advisers are required to report the value of turnover during the month in certain asset classes as well as on a per fund basis and for additional asset classes. | No requirement. |
| Reporting North American Industry Classification System (NAICS) codes | No requirement. | Large hedge fund advisers are required to report industry exposure using six-digit NAICS codes for each qualifying hedge fund. | Large hedge fund advisers are required to report industry exposures but may choose any level of classification within the NAICS hierarchal code system, such as the two-digit NAICS sector code. |
| Reference asset exposure reporting for qualifying hedge funds | No requirement. | Large hedge fund advisers are required to report detailed information about their qualifying hedge funds’ monthly portfolio exposure to reference assets. | No requirement generally but certain exposure reporting is required when filing a current report in response to Section 5, Item B. |
| Counterparty exposure reporting | Private fund advisers are required to report certain information on counterparty exposure. | Large hedge fund advisers are required to report exposure information in a consolidated counterparty exposure table for their qualifying hedge funds’ borrowing, collateral received, lending, and posted collateral, aggregated across all counterparties as of the end of each month. | Large hedge fund advisers are required to complete a simplified exposure table for their qualifying hedge funds and report borrowing-related disclosures. No requirement to report more granular information on counterparty exposure. |
| Rehypothecated reporting | Large hedge fund advisers must report the total amount of collateral and other credit support posted by counterparties to each qualifying hedge fund that may be and has been rehypothecated by each qualifying hedge fund, as well as the total amount of collateral and other credit support that the reporting fund has posted to counterparties that may be rehypothecated. | Large hedge fund advisers must report the total amount of collateral and other credit support posted by counterparties to each qualifying hedge fund that may be and has been rehypothecated by each qualifying hedge fund, as well as the total amount of collateral and other credit support that the reporting fund has posted to counterparties that may be rehypothecated, but not certain percentages related to collateral and credit support that may be rehypothecated. | No requirement. |
| Current report trigger | Large hedge fund advisers are required to file a current report “as soon as practicable, but no later than 72 hours” upon the occurrence of certain events for each qualifying hedge fund. | Large hedge fund advisers are required to file a current report “as soon as practicable, but no later than 72 hours” upon the occurrence of certain events for each qualifying hedge fund. | Large hedge fund advisers are required to file a current report “no later than 72 hours” upon the occurrence of certain events for each qualifying hedge fund. There is no requirement to file a current report “as soon as practicable.” |
| Current reporting concerning margin defaults and an inability to meet margin calls | Large hedge fund advisers are required to file a current report under Section 5, Item D for each qualifying hedge fund that is in margin default or is unable to meet a call for margin, collateral, or equivalents. | Large hedge fund advisers are required to file a current report under Section 5, Item D for each qualifying hedge fund that is in margin default or is unable to meet a call for margin, collateral, or equivalents. | No requirement. |
| Current reporting concerning certain operational events | Large hedge fund advisers are required to file a current report under Section 5, Item G for each qualifying hedge fund that experiences an operations event (i.e., a significant disruption or degradation of the qualifying hedge fund’s “critical operations”). Form PF defines “critical operations” as operations necessary for (1) the investment, trading, valuation, reporting, and risk management of the reporting fund or (2) the operation of the reporting fund in accordance with federal securities laws and regulations. | Large hedge fund advisers are required to file a current report under Section 5, Item G for each qualifying hedge fund that experiences an operations event (i.e., a significant disruption or degradation of the qualifying hedge fund’s “critical operations”). Form PF defines “critical operations” as operations necessary for (1) the investment, trading, valuation, reporting, and risk management of the reporting fund or (2) the operation of the reporting fund in accordance with federal securities laws and regulations. | Large hedge fund advisers are required to file a current report under Section 5, Item G for each qualifying hedge fund that experiences an operations event (i.e., a significant disruption or degradation of the qualifying hedge fund’s “critical operations”). Form PF defines “critical operations” as operations necessary for the investment, trading, valuation, reporting, and risk management of the reporting fund. There is no requirement to file a current report for a significant disruption or degradation of the qualifying hedge fund’s operation in accordance with federal securities laws and regulations. |
| Current reporting concerning the inability to satisfy redemption requests | Large hedge fund advisers are required to file a current report under Section 5, Item I for each qualifying hedge fund that (1) is unable to pay redemption requests or (2) has suspended redemptions and the suspensions last for more than five consecutive business days. | Large hedge fund advisers are required to file a current report under Section 5, Item I for each qualifying hedge fund that (1) is unable to pay redemption requests or (2) has suspended redemptions and the suspensions last for more than five consecutive business days. | Large hedge fund advisers are required to file a current report under Section 5, Item I for each qualifying hedge fund that has suspended redemptions and the suspensions last for more than five consecutive business days. There is no requirement to file a current report when a qualifying hedge fund is unable to pay redemption requests. |
| Quarterly event reporting for private equity fund advisers | Private equity fund advisers must submit quarterly reports about adviser-led secondary transactions, general partner removals, the termination of investment periods, and fund terminations. | Private equity fund advisers must submit quarterly reports about adviser-led secondary transactions, general partner removals, the termination of investment periods, and fund terminations. | No requirement. |
*This column outlines the Form PF requirements that are currently in effect, given the extension of the compliance date of the 2024 Form PF amendments.
**This column outlines the requirements of the 2024 Form PF amendments, the compliance date for which has been extended until October 1, 2026. Depending on the content and timing of any final amendments adopted from the Proposing Release, we expect that the compliance date for the 2024 Form PF amendments will become moot once amendments to Form PF based on the Proposing Release are adopted.