SEC Proposes Form PF Amendments: Key Changes to Filing Thresholds

On April 20, 2026, the SEC and CFTC proposed amendments to Form PF, introducing significant changes to filing thresholds and reporting requirements for private fund advisers. Designed to reduce reporting burdens while preserving systemic risk oversight, the proposal would result in fewer firms required to file and simplified reporting for those that remain in scope.

TL;DR: What You Need to Know About the SEC and CFTC Proposed Amendments to Form PF

The SEC’s proposed amendments to Form PF would significantly reduce reporting obligations for private fund advisers by raising filing thresholds and simplifying key requirements. Here’s a quick breakdown of the most important changes:

• The filing threshold would increase from $150M to $1B AUM, removing many smaller advisers from the requirement
• The large hedge fund adviser threshold would rise from $1.5B to $10B, reducing enhanced reporting obligations
• Several complex reporting elements would be eliminated, including certain exposure, volatility, and event reporting requirements
• Form PF will still be used to monitor systemic risk, meaning expectations around accuracy and consistency remain unchanged

A Meaningful Reduction in Scope

More than the threshold increases themselves; what matters is how they reshape who is required to file Form PF.

By raising the minimum filing threshold to $1 billion in private fund assets under management and increasing the “large hedge fund adviser” threshold to $10 billion, the SEC is effectively narrowing its focus to larger, more systemically relevant firms.

• Minimum filing threshold: $150M to $1B AUM
• Large hedge fund adviser threshold: $1.5B to $10B AUM

In practice, many smaller advisers may fall out of scope while others shift into less intensive reporting. A change the SEC frames as a calibration (not a retreat) as it maintains visibility into most private fund assets.

Less Complexity, More Standardization

Beyond thresholds, the Form PF amendments address a long-standing challenge with Form PF: operational complexity. Rather than layering on additional reporting, the SEC is removing several requirements that have proven difficult to implement consistently across firms.

These include:

• Certain “look-through” requirements for indirect exposures
• Performance volatility reporting
• Detailed counterparty exposure reporting
• Select current and event-driven reporting obligations

The practical impact is a shift toward more standardized, easier-to-produce information. For compliance teams, this reduces the burden of building bespoke calculations and reconciliations, particularly in areas where data inputs are fragmented or dependent on third parties.

Continued Focus on Systemic Risk

While the proposal reduces both scope and complexity, it does not change the purpose of Form PF. The SEC and CFTC are clear that the form will continue to support:

• FSOC’s systemic risk monitoring
• Oversight of private fund market activity
• Regulatory and examination programs

Rather than collecting increasingly granular data from a broad set of advisers, regulators are prioritizing coverage of key market participants and higher-quality data inputs.

Even if reporting requirements are reduced, expectations around accuracy, consistency, and alignment with actual practices remain firmly in place.

What This Means for Private Fund Advisers

At a surface level, the proposal reduces reporting – fewer filers, fewer data points, and less complexity. But the practical impact is more nuanced.

For some advisers, particularly those near current thresholds, this may result in a complete shift in filing obligations. Others will remain in scope but with a more streamlined reporting process. In both cases, the change is less about relief and more about refocusing compliance efforts.

The expectations from regulators have not changed. Form PF may require less information, but what remains will carry more weight. Firms will still be expected to ensure that:

• Data is accurate and supported
• Disclosures align with actual practices
• Reporting processes are consistent and defensible

As the rule moves through the comment period, firms should pay close attention to how final thresholds and reporting requirements are defined. But more importantly, this is an opportunity to reassess how Form PF fits within the broader compliance program.

Ultimately, the proposal signals a shift away from volume-driven reporting toward a more focused expectation that firms can clearly demonstrate control over the data that matters most.