SEC and CFTC propose amendments to Form PF

Background

On April 20, 2026, the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC and, together with the SEC, the Commissions) proposed amendments to Form PF (the 2026 Proposal), the confidential reporting form filed by SEC-registered investment advisers to private funds, including those that are registered with the CFTC as commodity pool operators or commodity trading advisers. 

Most significantly, the proposed amendments would:

• Raise the Form PF filing threshold for all filers, from $150 million in private fund assets under management to $1 billion;
• Raise the reporting threshold for large hedge fund advisers from $1.5 billion in hedge fund assets under management to $10 billion; and
• Streamline many Form PF requirements, including by: eliminating certain “look through” requirements; eliminating certain performance volatility reporting requirements; simplifying certain large hedge fund counterparty exposure reporting; modifying the timing requirements and eliminating certain current reporting requirements for large hedge fund advisers; eliminating quarterly event reporting for all private equity fund advisers; and making various corrections and other revisions.

Recent Form PF history.  Initially adopted in 2011 pursuant to the Dodd-Frank Act in order to assist the Financial Stability Oversight Council (FSOC) in monitoring systemic risk in the private fund industry, Form PF has been amended several times since its original adoption. Most recently:

•  In May 2023, the SEC adopted amendments requiring large hedge fund advisers to file current reports upon the occurrence of certain key events (Section 5), requiring all private equity fund advisers to file certain quarterly event reports (Section 6), and revising certain reporting requirements for large private equity fund advisers (Section 4). These amendments are currently in effect.
• In February 2024, the Commissions jointly adopted amendments to Form PF (the 2024 Amendments), which were intended to improve data quality, enhance systemic risk monitoring, and provide greater insight into private fund operations and strategies. The 2024 Amendments made significant changes to Sections 1 and 2 of Form PF, affecting all filers and large hedge fund advisers respectively. However, while the version of the form adopted under the 2024 Amendments is currently “effective,” the compliance date for the 2024 Amendments has been postponed multiple times and is currently set for October 1, 2026. As a result, most advisers are still filing the version of Form PF that was in effect prior to the 2024 Amendments.

Summary of key changes[1]

A. Filing and reporting threshold changes

The 2026 Proposal would raise the minimum threshold for filing Form PF from $150 million in private fund assets under management to $1 billion. The Commissions estimate that this change would eliminate filing obligations for nearly half of current Form PF filers, while continuing to capture approximately 94% of private fund gross assets under management (as calculated using applicable Form PF definitions).

The 2026 Proposal would also raise the reporting threshold for large hedge fund advisers — the advisers required to complete the more detailed Section 2 of Form PF and file quarterly — from $1.5 billion to $10 billion in hedge fund assets under management. The Commissions estimate that approximately two-thirds of current large hedge fund advisers would no longer be required to file as large hedge fund advisers under the proposed threshold, while the reporting would continue to cover approximately 81% of hedge fund gross assets.  The 2026 Proposal also contemplates that the SEC staff would be required to report to the SEC, on a five-year basis, whether the filing and reporting thresholds should be adjusted. 

Notably, the Commissions did not propose to increase the threshold for what constitutes a “qualifying hedge fund” — i.e., a hedge fund advised by a large hedge fund adviser that, together with its feeder and parallel funds and certain other parallel accounts, had a net asset value of at least $500 million as of month-end in the fiscal quarter immediately preceding the adviser’s most recently completed quarter. The Commissions did, however, solicit comment on whether this threshold should also be increased. 

B. Changes to general instructions

Master-feeder and parallel fund structures.  The 2024 Amendments required advisers to report each component fund of a master-feeder arrangement and parallel fund structure separately, with a limited exception for “disregarded feeder funds” — feeder funds that invest all of their assets in a single master fund, U.S. treasury bills, and/or cash and cash equivalents. The 2026 Proposal would expand this exception by permitting a feeder fund to be treated as a disregarded feeder fund if it invests no more than 5% of its gross asset value in assets outside of a single master fund, U.S. treasury bills, and/or cash and cash equivalents. This change is designed to reduce the reporting burden associated with disaggregated reporting of master-feeder structures where a feeder fund holds only de minimis assets outside of its interest in the master fund.

Look-through requirements.  The 2024 Amendments introduced prescriptive “look-through” requirements directing advisers to look through a reporting fund’s investments in other funds and entities when reporting indirect exposures in response to certain questions (Questions 32, 33, 35, 36, and 47). The 2026 Proposal would eliminate these prescriptive look-through requirements and instead permit advisers to report indirect exposures based on reasonable estimates consistent with their internal methodologies and conventions of service providers. Conforming changes would be made to the instructions to the affected questions and to certain asset class definitions in the Glossary of Terms.

Trading vehicles. The 2024 Amendments required advisers to identify all trading vehicles — separate legal entities used to hold assets, incur leverage, or conduct trading as part of a fund’s investment activities — regardless of their nature or size. The 2026 Proposal would significantly narrow this requirement: advisers would only be required to identify trading vehicles that are either (i) listed or required to be listed on the adviser’s Form ADV or (ii) identified in responses to certain counterparty exposure questions (Questions 27, 28, 42, 43, or 44). This change is intended to exclude passive vehicles used for tax, regulatory, or structural purposes that do not directly interact with the market in a manner relevant to systemic risk.

C. Changes to Section 1 — all filers

Performance volatility reporting (Q23(c)). The 2024 Amendments added a new requirement for advisers that calculate daily market values for any position in a reporting fund’s portfolio to report additional performance-related information, including the fund’s aggregate calculated value, monthly annualized volatility of daily log returns, and certain drawdown metrics. The 2026 Proposal would eliminate this requirement entirely. The Commissions found that this question was operationally burdensome for many advisers, did not produce comparable reporting across filers due to differing internal methodologies, and was of limited incremental value given the availability of performance information from other parts of the form.

Trading and clearing mechanisms (Q29 and Q30). The 2024 Amendments required advisers, with respect to all hedge fund clients, to report both (i) the value of transactions during the reporting period and (ii) the value of positions at the end of the reporting period, broken out by instrument category and trading mode. The 2026 Proposal would eliminate the end-of-period position value reporting from both Q29 and Q30, retaining only the value-traded column. The Commissions found that end-of-period position data was burdensome to compile and that similar information could be inferred from other parts of the form. 

All other significant changes to Section 1 introduced by the 2024 Amendments — including expanded fund type identification, new open-end/closed-end classification, monthly gross and net asset value reporting, contributions and withdrawals reporting, expanded beneficial ownership categories, and detailed counterparty exposure questions (Q26, Q27, Q28) — are retained in the 2026 Proposal.

D. Changes to Section 2 — large hedge fund adviser reporting of qualifying hedge funds

This section saw the most significant changes in the 2026 Proposal, with several of the 2024 Amendments’ most substantial new requirements for qualifying hedge funds advised by large hedge fund advisers being eliminated or simplified.

Adjusted exposure — internal methodology alternative eliminated (Q32(b)(2)). The 2024 Amendments required advisers to calculate adjusted (netted) exposure using a prescribed methodology (Q32(b)(1)) and, if the adviser’s internal methodology differed, to also report adjusted exposure under its internal methodology (Q32(b)(2)). The 2026 Proposal would eliminate Q32(b)(2), retaining only the prescribed methodology. The Commissions viewed Q32(b)(2) as duplicative. Notably, however, advisers that do not net all positions across all instrument types internally will now have no alternative but to use the prescribed methodology.

Portfolio turnover eliminated (Q34). The 2024 Amendments moved the portfolio turnover question from the now-eliminated Section 2a to a per-fund basis in Section 2 and significantly expanded the categories of assets for which turnover must be reported. The 2026 Proposal would eliminate Q34 entirely. The Commissions found that turnover data was an imprecise signal of systemic risk and that the per-fund, monthly reporting requirement was significantly more burdensome than advisers had anticipated.

NAICS code flexibility (Q36).  The 2024 Amendments added Q36, which requires reporting of a qualifying hedge fund’s exposures by industry, based on the NAICS code of the underlying exposures, if the exposure exceeds certain thresholds (5% of NAV or $1 billion). The 2026 Proposal modifies Q36 to permit advisers to use any level of NAICS code (2-6 digits) rather than requiring the full 6-digit code.

Reference asset concentration reporting eliminated (Q39 and Q40). The 2024 Amendments introduced two entirely new questions requiring monthly reporting of concentration data at the individual reference asset level. Q39 required reporting of the total number of reference assets to which the fund has netted exposure, and the percentage of NAV represented by the top five and top 10 netted exposures. Q40 required detailed identifying and sizing information for any reference asset where the fund’s gross exposure exceeded certain thresholds (5% of NAV, $1 billion, or 1% of NAV combined with a large share of the relevant market). The 2026 Proposal would eliminate both Q39 and Q40 entirely. The Commissions acknowledged that these questions were operationally complex and the calculations required were not aligned with how advisers track their portfolios internally. To partially offset the loss of this data, the 2026 Proposal would add a new field to the Section 5 extraordinary loss current report (Item B) requiring advisers to describe the largest exposure contributing to the reported loss, including identifying information about the relevant reference asset.

Consolidated counterparty exposure table simplified (Q41 Eliminated). The 2024 Amendments introduced a detailed consolidated counterparty exposure table (Q41) for qualifying hedge funds, requiring monthly reporting of borrowing and collateral data broken out by transaction type, creditor type, and collateral type, including an estimate of the expected increase in collateral required if the margin increases by 1% of position size. The 2026 Proposal would eliminate Q41 entirely. Instead, qualifying hedge funds would complete the simpler consolidated counterparty exposure table in Question 26 (currently applicable to non-qualifying hedge funds), but on a monthly basis rather than only at period-end. The Commissions acknowledged that Q41’s granular collateral categorization requirements were particularly problematic because prime brokers typically report collateral on a pooled basis that does not align with the form’s required breakdowns.

Individual counterparty reporting modified (Q42 and Q43). The 2024 Amendments required advisers to identify significant creditors (Q42) and significant net mark-to-market counterparties (Q43) using cash borrowing entries and cash lending entries as the relevant measures. The 2026 Proposal would expand these questions to use all borrowing entries and all lending entries (not just cash), potentially capturing a broader set of counterparties and providing a more expanded view of counterparty exposure. The 2026 Proposal would also simplify the collateral breakdown required for the top five counterparties in Q42(a) to align with the less granular categories used in Q26, and would add a new requirement in Q42(b) to categorize borrowings by type (unsecured, prime brokerage, repo, other secured, cleared/uncleared derivatives). 

Rehypothecation reporting eliminated (Q45). The 2024 Amendments retained a requirement (carried forward from the original 2011 form) for large hedge fund advisers to report the percentage of collateral received from counterparties that may be and has been rehypothecated. The 2026 Proposal would eliminate Q45 entirely. The Commissions found that the data produced was unreliable because advisers cannot readily determine rehypothecation from omnibus accounts, resulting in rough estimates that are not comparable across filers.

Market factor stress testing — minor modifications (Q47). The 2024 Amendments significantly revised Q47 by requiring advisers to respond to all listed market factors (previously optional), modifying the stress thresholds, and adding non-parallel interest rate movement scenarios. These changes are retained in the 2026 Proposal. 

E. Changes to Section 5 — current reports (large hedge fund advisers)

Filing deadline — “as soon as practicable” language removed. The current Section 5 requires advisers to file current reports “as soon as practicable, but no later than 72 hours” after the “occurrence” of certain reportable events. The 2026 Proposal would remove the “as soon as practicable” language, giving advisers a clear 72-hour deadline with no additional obligation to file earlier. The Commissions acknowledged that the “as soon as practicable” standard created uncertainty and required advisers to consult with counsel to determine when filing was required within the 72-hour window.  However, advisers will still need to assess when a reportable event should be deemed to have “occurred,” which in some cases will still require difficult exercises of judgment. 

New disclosure added to extraordinary loss report (Item B). As noted above in connection with the elimination of Q39 and Q40, the 2026 Proposal would add a new required field to Item B (extraordinary investment loss current reports) requiring advisers to describe the largest exposure contributing to the reported loss, including the dollar amount, sub-asset class, instrument type, title or description of the asset, and identifying information about the issuer.

Margin default current report eliminated (Item D). The 2024 Amendments (building on the 2023 amendments) required advisers to file a current report if a qualifying hedge fund is in default on a margin call or the adviser determines the fund is unable to meet a margin call. The 2026 Proposal would eliminate Item D entirely. The Commissions noted that margin defaults are likely already captured by the extraordinary loss (Item B) or margin increase (Item C) current reporting triggers, and that the lack of a materiality threshold made Item D operationally burdensome to monitor.

Operations event definition narrowed (Item G). The current Item G requires a current report when the reporting fund or adviser experiences a significant disruption or degradation of the fund’s “critical operations,” defined to include both (i) operations necessary for investment, trading, valuation, reporting, and risk management and (ii) operations necessary for compliance with federal securities laws. The 2026 Proposal would eliminate the second prong of this definition. Going forward, an operations event would only be reportable if it disrupts or degrades operations necessary for investment, trading, valuation, reporting, and risk management. The Commissions found that the second prong was too vague and created uncertainty about what events were reportable. 

Inability to pay redemptions eliminated (Item I, First Prong). Item I currently requires a current report if a qualifying hedge fund (i) is unable to pay redemption requests or (ii) suspends redemptions for more than five consecutive business days. The 2026 Proposal would eliminate the first prong, retaining only the suspension of redemptions trigger. The Commissions found that the first prong was interpreted inconsistently across advisers — in particular, whether in-kind redemptions constitute a failure to satisfy redemption requests was unclear — resulting in reporting that was not comparable or useful.

F. Changes to Section 6 — quarterly private equity event reports

The 2026 Proposal would eliminate Section 6 in its entirety. Section 6, which was added by the 2023 amendments, requires all private equity fund advisers to file quarterly reports upon the occurrence of certain events: adviser-led secondary transactions, general partner removals, termination of investment periods, and fund terminations.

The SEC noted that, after more than two years of receiving Section 6 filings, the reported events have proven to be more idiosyncratic and firm-specific than anticipated, and have not served as reliable indicators of broader market trends or systemic risk. Given the relatively low frequency of Section 6 filings and the disproportionate burden they impose on private equity fund advisers — who must file on a timeframe separate from their regular annual Form PF reporting cycle — the SEC concluded that the costs of maintaining Section 6 outweigh its benefits. Private equity fund advisers would no longer be required to report any of the events currently covered by Section 6.

G. Request for comment on private credit reporting

Although not a proposed amendment, the 2026 Proposal includes a request for public comment on whether Form PF should be modified to include reporting specifically tailored to private credit funds. The Commissions noted that the private credit industry has grown significantly since Form PF was originally adopted and that the current form does not include a dedicated section or definition for private credit funds. The Commissions requested comment on a range of questions, including whether a new section or subsection should be added for private credit funds, how “private credit” and “private credit fund” should be defined, what data elements should be collected, and whether private credit funds should be subject to current event reporting under Section 5. While this is a request for comment rather than a proposed rule, it signals that private credit reporting may be an area of focus in future Form PF rulemaking.

H. Proposed transition period

The 2026 Proposal contemplates a minimum 12-month transition period from the date of publication of any final amendments in the Federal Register. Given that the compliance date for the 2024 Amendments is currently set for October 1, 2026, the Commissions indicated that they will consider how the timing of any final 2026 amendments relates to that date. Advisers should monitor developments closely, as it remains possible that the compliance dates for the 2024 Amendments and any final 2026 amendments could be aligned, allowing advisers to implement both sets of changes simultaneously.

Areas of continued burden

While the 2026 Proposal is framed as a deregulatory initiative and does provide meaningful relief in several areas — most notably by increasing filing thresholds, eliminating Q34, Q39, Q40, Q41, and Q45, simplifying the trading vehicle identification requirement, and eliminating Section 6 — it is important to note that a number of questions included in the 2024 Amendments that the industry has viewed as particularly burdensome are retained in full in the 2026 Proposal.

• Gross exposure by sub-asset class and instrument type (Q32(a)): Industry commenters argued strenuously that requiring position-level reporting by instrument type — distinguishing between, for example, physical holdings, futures, swaps, ETFs, and other indirect exposures across an expanded list of sub-asset classes — does not reflect how advisers manage or track their portfolios internally, would require significant new systems development, and raised data security concerns. The 2026 Proposal retains Q32(a) in full, with only modest flexibility for reporting of indirect exposures.
• Adjusted exposure using prescribed netting methodology (Q32(b)(1)): Commenters objected to the prescribed netting methodology as burdensome and inconsistent with internal risk management practices. The 2026 Proposal not only retains Q32(b)(1) but eliminates the internal methodology alternative (Q32(b)(2)) that was intended to provide some flexibility. All advisers must now use the prescribed methodology regardless of how they calculate economic exposure internally.
• Monthly country exposure reporting (Q35): Commenters argued that monthly country-level reporting was operationally burdensome, particularly for funds with significant indirect exposures, and questioned its marginal value for systemic risk monitoring. Q35 is retained in the 2026 Proposal with only modest flexibility through the “best represents” standard for indirect exposures.
• Counterparty exposure reporting (Q26, Q42, Q43): The industry raised significant concerns about the consolidated counterparty exposure table framework, particularly the difficulty of breaking out collateral by asset type when prime brokers report on a pooled basis, and the complexity of netting instructions in the context of cross-margining arrangements. While the 2026 Proposal provides some relief by eliminating Q41 and directing qualifying hedge funds to use the simpler Q26 table, the core operational challenges identified by commenters persist. 
• CCP identification (Q44): Commenters argued that individual CCP identification was burdensome and that aggregate reporting would be sufficient for systemic risk monitoring purposes. Q44 is retained without modification.
• Mandatory market factor stress testing (Q47): Commenters objected to the requirement to respond to all listed market factors regardless of a fund’s actual exposures, arguing it would produce meaningless responses for inapplicable factors. This requirement is retained in the 2026 Proposal.

The 2026 Proposal’s comment period provides an additional opportunity for the industry to provide feedback on these items.

[1] The 2026 Proposal would make a number of additional corrections and technical revisions, including:

— Revising section headings to consistently identify which types of advisers are required to complete each section;

—  Correcting erroneous instructions in Sections 3 and 4 that mistakenly stated advisers may report master-feeder and parallel fund structure components on an aggregate basis (contrary to the 2024 Amendments’ disaggregated reporting requirement);

—  Moving certain instructions specific to Question 25 from General Instruction 15 to Question 25 itself, for clarity;

—  Correcting Question 33(a) to align the question text with the table (which correctly requires “long value” and “short value” rather than “net long value” and “net short value”);

—  Adding an instruction to Question 47 specifying the mathematical sign convention for reporting the effect of market factor changes on long and short portfolio components;

—  Correcting an error in the Glossary definition of “large private equity fund adviser,” which erroneously referred to “Section 4a” rather than “Section 4”; and

—  Adding an instruction to Questions 27 and 42 to specify that advisers must report the legal entity name (in addition to the LEI) of affiliated counterparty entities in cross-margining arrangements.