The U.S. Securities & Exchange Commission and the U.S. Commodity Futures Trading Commission jointly proposed amendments to Form PF to cut private fund reporting burdens while preserving information used for Financial Stability Oversight Council systemic-risk monitoring and the agencies’ investor-protection work. The package would materially narrow the population of SEC-registered advisers required to file and roll back or simplify a wide range of hedge fund and private equity reporting items. Key threshold changes include raising the Form PF filing threshold from USD 150 million to USD 1 billion in private fund assets under management and lifting the “large” hedge fund adviser threshold from USD 1.5 billion to USD 10 billion in hedge fund assets under management, while stating Form PF would still capture over 90% of private fund gross assets and over 80% of hedge fund gross asset value. The proposal also pares back requirements by, among other changes, easing master-feeder reporting via a five percent de minimis test for disregarded feeder funds, allowing reasonable estimates in lieu of prescriptive “look through” calculations for indirect exposures, narrowing trading-vehicle identification, removing certain performance volatility, turnover, rehypothecation, and reference-asset concentration reporting, simplifying counterparty exposure tables and current reporting triggers, and eliminating private equity quarterly event reporting in section 6. It also introduces a mechanism to identify funds active in private credit and seeks comment on whether private credit reporting should be modified, alongside a proposed SEC staff review of Form PF thresholds around five years after the amendments’ compliance date and every five years thereafter. Comments are requested on all aspects of the proposal, with a 60-day comment period following Federal Register publication. The agencies also propose a minimum 12-month transition period after Federal Register publication and note the existing compliance date for the 2024 Form PF amendments remains October 1, 2026, with timing alignment to be considered.
U.S. Securities & Exchange Commission 2026-04-20
U.S. Securities & Exchange Commission and U.S. Commodity Futures Trading Commission propose to raise Form PF thresholds to USD 1 billion and USD 10 billion and streamline private fund reporting
The U.S. Securities and Exchange Commission and the U.S. Commodity Futures Trading Commission jointly proposed amendments to Form PF to reduce private fund reporting burdens while preserving data needed for systemic-risk monitoring and investor protection. The proposal would raise the Form PF filing threshold from USD 150 million to USD 1 billion and the “large” hedge fund adviser threshold from USD 1.5 billion to USD 10 billion, simplify or eliminate multiple reporting items, introduce a mechanism to identify funds active in private credit, and require SEC review of Form PF thresholds about every five years.