On April 20, 2026, the Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”) jointly proposed substantial amendments to Form PF, which would meaningfully alter the scope and nature of private fund reporting for investment advisers.
Form PF is currently required to be filed by SEC-registered investment advisers (including those also registered with the CFTC as commodity pool operators or commodity trading advisers) that, together with their related persons, have at least $150 million in private fund assets under management. Large hedge fund, liquidity fund, and private equity fund advisers are also subject to enhanced reporting requirements.
Proposed Changes to Filing and Reporting Thresholds
The proposed amendments would significantly increase the thresholds triggering Form PF filing and enhanced reporting obligations. Specifically, the general Form PF filing threshold would be raised from $150 million to $1 billion in private fund assets under management, and the reporting threshold for large hedge fund advisers would increase from $1.5 billion to $10 billion in hedge fund assets under management. According to the SEC, these threshold changes would result in approximately 43% fewer advisers being required to file Form PF and 65% fewer advisers being subject to large hedge fund adviser reporting requirements. Although the proposal does not include corresponding increases to the thresholds for enhanced reporting by large liquidity fund advisers or large private equity fund advisers, the SEC has expressly solicited comment on whether those thresholds should also be increased.
Streamlining and Elimination of Certain Reporting Requirements
The proposed amendments would also streamline—or eliminate entirely—numerous existing reporting obligations, including:
- Elimination of quarterly event reporting for private equity funds;
- Elimination of current event reporting by large hedge fund advisers relating to the inability to meet redemption requests, certain operational events, and certain margin defaults;
- Elimination of separate reporting for feeder funds with de minimis holdings outside of a single master fund, U.S. treasury bills and/or cash and cash equivalents;
- Removal of the requirement to “look through” a reporting fund’s investments in other private funds and entities, instead permitting reporting of indirect exposures based on reasonable estimates; and
- Elimination or simplification of several hedge fund–specific data points that must be reported by large hedge fund advisers, including, monthly turnover by asset class, rehypothecation, adjusted exposure netting based on an adviser’s internal methodologies, monthly exposures to reference assets and counterparty exposure.
Private Credit Reporting
In addition to the proposed increases to filing and reporting thresholds, the SEC has requested comments on whether and how private credit activity should be addressed in Form PF. The SEC is soliciting feedback on whether it should define the terms “private credit” or “private credit fund,” add a new private credit section or subsection to Form PF, or include additional questions tailored to private credit-related filers. The SEC has also requested that commenters share what they believe to be the greatest risks from a systemic risk perspective posed by private credit markets and private credit funds. This request for comment signals a growing focus on private credit markets and an acknowledgement by regulators of the usefulness of gathering additional data relating to private credit funds in order to inform systemic risk assessment.
Looking Forward
If adopted, the proposed amendments would substantially reduce Form PF reporting burdens, streamline required disclosures and recalibrate regulatory data collection toward information more directly relevant to the monitoring of potential systemic risks. Moreover, as noted by SEC Commissioner Hester M. Peirce in her statement accompanying the proposal, the amendments may present an opportunity to further reduce reporting obligations through the comment process. Advisers pursuing private credit strategies, in particular, should closely evaluate the proposal, which reflects an increased SEC focus on the systemic risk implications of private credit activities. Accordingly, advisers to private funds may wish to review the proposal in detail and consider submitting comments. The comment period will remain open until June 23, 2026.
For additional information on the proposed changes to Form PF, please contact a member of Seward & Kissel’s Investment Management Group.