United States: Form PFffft: SEC and CFTC Propose Rolling Back Reporting Burdens for Private Fund Managers

By: Thoreau A. Bartmann, Richard W. Burnett, Ruth E. Delaney, Lance C. Dial, Pablo J. Man, and Sarah V. Riddell

On 20 April 2026, the SEC and CFTC jointly proposed yet another round of amendments to Form PF to eliminate filing obligations for many private fund advisers and reduce burdens for many of those who remain subject to the form.

Form PF was originally adopted as a means to monitor systemic risk in the financial markets. However, over time the form’s requirements expanded significantly, particularly in 2023 and 2024, prompting significant pushback from industry participants who raised concerns about the technological and administrative burdens of compliance. This proposal reflects a fresh look at the Form, taking it “back to basics.” The key changes include:

• Higher Reporting Thresholds: The proposal would raise the filing threshold from US$150 million to US$1 billion in private fund assets under management. The large hedge fund adviser reporting threshold would also rise from US$1.5 billion to US$10 billion in hedge fund assets under management. These changes would reduce by almost 50% the number of advisers required to file the form, likely affecting the number of reporting advisers, which could have implications for those who rely on CFTC registration relief under CFTC Letter No. 25-50, which conditions the relief on filing Form PF.
• Reduced Current Reporting: The proposal would eliminate certain “current reporting” for large hedge fund advisers as well as quarterly event reporting for all private equity fund advisers. The current reporting requires significant ongoing burdens to ensure compliance.
• Overall Streamlining: For advisers who remain subject to the form, the proposal would eliminate look-through requirements for master-feeder vehicles, remove performance volatility reporting, and simplify large hedge fund counterparty exposure reporting, among many other changes.

Comments are due 60 days after publication in the Federal Register. Please reach out to our team to discuss what this means for your reporting obligations or for assistance preparing a comment letter.