On April 24, 2026, the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) jointly announced a proposal to amend Form PF, the confidential reporting instrument for certain SEC-registered investment advisers to private funds. This move, detailed in File No. S7-2026-13 and RIN 3038-AF68 for the CFTC, and RIN 3235-AN64 for the SEC, is designed to reduce the reporting burden on investment advisers while ensuring the continued collection of data vital for investor protection and the assessment of systemic risk within the U.S. financial system.
Origins and Purpose of Form PF
Form PF traces its origins to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. This landmark legislation mandated that the SEC and CFTC, in consultation with the Financial Stability Oversight Council (FSOC), establish a comprehensive reporting framework for private funds. The aim was to enhance transparency and provide regulators with critical insights into the activities of an increasingly complex financial sector. The Advisers Act specifically requires advisers to maintain records on aspects such as assets under management, leverage, counterparty risk, trading positions, and valuation policies. Form PF was first adopted in 2011 and has undergone several amendments since, including substantive changes in 2023 and 2024 that introduced current reporting for large hedge funds and quarterly reporting for private equity funds.
Key Proposed Amendments
The Commissions' latest proposal introduces a broad array of modifications intended to streamline the reporting process and alleviate perceived redundancies or excessive burdens. These amendments fall into several key categories:
Adjusted Filing and Reporting Thresholds
One significant change involves increasing the filing threshold for all Form PF filers and raising the reporting threshold for large hedge fund advisers. This adjustment would reduce the number of entities required to file or report at certain levels, thereby directly cutting compliance costs for smaller or less systemically significant advisers.
Elimination and Streamlining of Specific Reporting Requirements
The proposal seeks to eliminate or simplify numerous granular data points that the Commissions believe may no longer be necessary or could be obtained more efficiently. These include:
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Disregarded Feeder Funds and Look-Through Requirements: Eliminating certain reporting obligations related to these structures.
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Trading Vehicles: Revisions concerning how these are reported.
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Volatility Reporting: Specifically, the removal of Form PF Question 23(c).
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Certain Trading and Clearing Reporting: Reducing the scope of data required in these areas.
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Adjusted Exposure Reporting: Eliminating Question 32(b)(2) which relies on internal methodologies.
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Monthly Asset Turnover Reporting: Removing Form PF Question 34.
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Industry Concentration Reporting: Simplifying Form PF Question 36.
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Qualifying Hedge Fund Exposures: Eliminating certain questions related to exposures to reference assets.
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Counterparty Exposure Reporting: Simplifying the requirements for large hedge fund advisers.
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Rehypothecation Reporting: Eliminating this specific data point.
Amendments to Large Hedge Fund Adviser Current Reporting
For large hedge fund advisers, the proposal suggests several changes to current reporting obligations, which were notably enhanced in 2023. These amendments include:
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Modified Filing Deadlines: Adjustments to when current reports must be submitted.
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Elimination of Margin Default Reporting: Removing the requirement to report notice of margin default or inability to meet a call for margin, collateral, or equivalents.
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Streamlined Operations Events: Simplifying the reporting of certain operational occurrences.
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Elimination of Redemption Request Inability Reporting: Removing the requirement to report the inability to satisfy redemption requests.
Elimination of Private Equity Quarterly Reporting
Notably, the proposal also seeks to eliminate the private equity quarterly reporting requirements found in Section 6 of Form PF. This change would represent a substantial reduction in the periodic reporting burden for advisers to private equity funds.
Rationale and Call for Comment
The Commissions emphasize that these proposed amendments are designed to strike a balance: eliminating certain burdens while ensuring Form PF continues to collect information that is necessary and appropriate in the public interest, for the protection of investors, or for the assessment of systemic risk by the FSOC. The proposal includes a detailed economic analysis of the anticipated benefits and costs, as well as potential effects on efficiency, competition, and capital formation.
Public comment is a crucial component of this rulemaking process. The CFTC and SEC are soliciting feedback on all aspects of the proposed rules, including specific questions related to private credit reporting and a proposed transition period for implementation. Comments on the proposal were due on or before June 23, 2026, and stakeholders were encouraged to submit their input through designated portals on the CFTC and SEC websites, or via mail, referencing File Number S7-2026-13.
Looking Ahead
This joint proposal signals an adaptive approach to regulatory oversight, acknowledging that reporting requirements should evolve with market understanding and technological capabilities. The outcome will depend on the public comments received and the Commissions' final assessment of how best to balance comprehensive data collection with the practicalities of compliance for the private funds industry.
