Form PF is a confidential regulatory reporting form for private fund investment advisers registered with the U.S. Securities and Exchange Commission (SEC), including advisers that are also registered with the Commodity Futures Trading Commission (CFTC) in relevant capacities. It is intended to provide information to the SEC, CFTC, and Financial Stability Oversight Council (FSOC) for systemic risk monitoring and related regulatory purposes. Form PF applies to SEC-registered advisers that have at least $150 million in private fund assets under management as of the last day of the most recently completed fiscal year.
Recent Form PF rulemaking has materially expanded reporting. In May 2023, the SEC and CFTC adopted amendments that introduced new current reporting for large hedge fund advisers and quarterly event reporting for private equity fund advisers.
In February 2024, the SEC and CFTC adopted further Form PF amendments requiring more detailed reporting. Those amendments included changes affecting reporting methodologies, fund structure treatment, and detailed exposures and counterparty reporting. However, following later developments—including a presidential memorandum and market participant feedback—the SEC and CFTC jointly extended the compliance date for those 2024 amendments to October 1, 2026 to allow further review and possible additional action.
The Proposed Rule’s Key Form PF Changes
The Proposed Rule is expressly framed as a burden-reduction initiative designed to preserve information considered necessary for investor protection and FSOC systemic-risk monitoring while eliminating or simplifying a number of Form PF obligations.
Higher general Form PF filing threshold
The Proposed Rule would raise the baseline Form PF filing threshold for all filers from $150 million in private fund assets under management to $1 billion. The Proposed Rule estimates that this would eliminate filing obligations for many smaller advisers—described as almost half of current filers—while preserving reporting on more than 90% of private fund gross assets.
Higher threshold for “large hedge fund adviser” status
The Proposed Rule would raise the reporting threshold for large hedge fund advisers from $1.5 billion in hedge fund assets under management to $10 billion, which would mean that those advisers falling beneath the new proposed threshold would no longer be subject to the enhanced quarterly, current-reporting regime for large hedge fund advisers. The Proposed Rule estimates that this would eliminate certain quarterly and current-reporting obligations for many advisers that now report as large hedge fund advisers, while still collecting quarterly information on over 80% of hedge fund gross assets.
Elimination of specified data elements and reporting requirements
| Proposal | Current Requirement | Proposed Change |
|---|---|---|
| Eliminate separate reporting for certain feeder funds | Each component fund in master-feeder and parallel fund structures must generally be reported separately, subject to limited exceptions. | Permits aggregation of reporting for feeder funds with only de minimis assets outside a single master fund, Treasury bills, and/or cash equivalents. |
| Eliminate “look through” requirements | Filers must “look through” investments in certain private funds and entities when reporting indirect exposures. | Allows indirect exposures to be reported using reasonable estimates aligned with internal methodologies and service-provider conventions. |
| Eliminate identification requirements for certain trading vehicles | Advisers must identify all trading vehicles through which a fund holds assets, incurs leverage, or conducts activity. | Narrows identification to a smaller set of trading vehicles. |
| Eliminate certain performance volatility reporting requirements | Daily market value calculation triggers reporting of aggregated values, return volatility, and related metrics. | Eliminates required volatility and daily-based performance reporting. |
| Eliminate certain trading and clearing reporting requirements | Filers must report both the value traded during the period and the value of positions at period-end. | Removes end-of-period position value reporting, while retaining traded-value data. |
| Eliminate portfolio turnover reporting | Large hedge fund advisers must report monthly turnover by asset class for qualifying hedge funds. | Eliminates monthly portfolio turnover reporting. |
| Eliminate certain reference-asset exposure reporting | Detailed monthly reporting is required for large hedge fund advisers for concentrated position-level reference asset exposures. | Eliminates detailed reference-asset reporting; substitutes targeted disclosure in extraordinary loss current reports. |
| Eliminate rehypothecation reporting | Large hedge fund advisers must report amounts of collateral that may be and has been rehypothecated. | Eliminates rehypothecation reporting. |
| Eliminate current reporting for large hedge fund advisers for certain margin defaults | Requires current reporting for large hedge fund advisers if their qualifying hedge fund is in margin default or is unable to meet margin/collateral calls. | Eliminates current reporting tied specifically to margin defaults and inability to meet margin/collateral calls. |
| Eliminate current reporting for certain operations events for large hedge fund advisers | Operations events reporting includes disruptions affecting (1) the investment, trading, valuation, reporting, and risk management of the reporting fund; or (2) the operation of the reporting fund in accordance with federal securities laws and regulations. | Narrows operations events by removing the federal securities laws and regulations prong. |
| Eliminate current reporting on the inability to satisfy redemption requests for large hedge fund advisers | Requires reporting if a fund is unable to pay redemption requests or suspends redemptions beyond five consecutive business days. | Eliminates reporting for inability to pay redemptions while retaining suspension of redemptions reporting. |
| Eliminate quarterly event reporting for all private equity fund advisers | Private equity advisers must file quarterly event reports under Section 6 involving adviser-led secondary transactions, general partner removals, termination of investment periods, and fund terminations. | Eliminates these quarterly private equity event reports. |
Streamlining of specified data elements and reporting requirements
| Proposal | Current Requirement | Proposed Change |
|---|---|---|
| Modify the current reporting trigger for all current reports for large hedge fund advisers | Current reports for large hedge fund advisers must be filed as soon as practicable but no later than 72 hours. | Removes the as-soon-as-practicable standard and provides a uniform 72-hour window for large hedge fund advisers. |
| Simplify certain large hedge fund counterparty exposure reporting | Large hedge fund advisers must complete detailed consolidated counterparty exposure tables. | Replaces complex tables with simplified aggregate reporting and focused disclosure on significant counterparties. |
| Reduce burdens associated with NAICS code reporting for large hedge fund advisers | For large hedge fund advisers, industry exposure reporting must use six-digit NAICS codes. | Allows reporting at fewer NAICS digits, providing greater flexibility. |
| Streamline adjusted exposure reporting | Large hedge fund advisers must report adjusted exposure using standardized methods and internal methodologies. | Eliminates adjusted exposure reporting based on internal methodologies. |
| Request for comments on private credit reporting | The SEC and CFTC are requesting comments on whether to modify the information that advisers must report about private credit funds. | |
Practical Implications for Private Fund Advisers
Compliance burdens and reporting workflows
If adopted, the Proposed Rule would substantially reduce compliance burdens for advisers below the new thresholds and for many mid-sized hedge fund advisers that currently qualify as large hedge fund advisers.
For advisers remaining within scope, the elimination or simplification of look-through, volatility, and counterparty exposure reporting could reduce dependence on manual data aggregation across fund structures, service providers, and affiliates.
Systems changes and implementation planning
The Proposed Rule may permit some firms to defer or resize technology builds that were designed for the delayed 2024 amendments, particularly builds focused on more granular exposures, complex structure look-through, or expanded counterparty reporting. But because the rule is only proposed, firms should be cautious about dismantling implementation projects prematurely; current requirements remain effective, and the October 1, 2026 delayed compliance date for the 2024 amendments is still the operative date until there is further rulemaking.
Advisers should continue to implement necessary measures for current and delayed requirements while noting systems and workflows that could be scaled back if the 2026 Proposed Rule is adopted substantially in the same form as put forth in the SEC release.
Examination and enforcement risk
The Proposed Rule could reduce exposure to SEC examination and enforcement by eliminating certain event-based triggers and narrowing the adviser population subject to filing.
However, advisers should assume the SEC staff will continue to use Form PF for examination scoping and as a cross-check against other disclosures and books-and-records. Firms should therefore avoid interpreting the Proposed Rule itself as a relaxation of present-day compliance expectations.
Interaction with other SEC and CFTC reporting
Because Form PF is jointly administered by the SEC and CFTC and applies to certain advisers with CFTC registrations or commodity pool / commodity trading advisor connections, any reduction in Form PF obligations may simplify overlapping reporting and internal control processes for dual registrants. Streamlining large hedge fund counterparty exposure reporting and eliminating certain event reports may reduce duplicative internal reconciliations across SEC, CFTC, and investor-reporting workstreams.
However, the Proposed Rule does not eliminate the broader need to maintain coherent data governance across regulatory filings. Advisers will still need consistency among Form ADV, books-and-records, offering documents, investor communications, CFTC filings where applicable, and any remaining Form PF responses.
Potential Upcoming Actions, Comment Timing, and Implementation Risks
The public comment period will remain open for 60 days after the Proposed Rule is published in the Federal Register.
Key implementation risks and uncertainties include:
- Final Scope Uncertainty. The SEC and CFTC may revise thresholds or retain more event reporting than the Proposed Rule currently suggests.
- Timing Uncertainty. There is no final effective or compliance date for the 2026 Proposed Rule, while the delayed October 1, 2026 compliance date for the 2024 amendments remains on the books.
- Operational Planning Risk. Advisers may face stranded implementation costs if they continue building for the 2024 amendments and those requirements are later narrowed, but they also risk under-preparation if they pause too early and the rollback is not adopted in time.
- Political/Regulatory Transition Risk. Because the Proposed Rule is tied to the current Administration’s deregulatory posture and references a presidential memorandum, final action could be sensitive to political developments, interagency priorities, and the public comment record.
- Examination Risk During Transition. The Proposed Rule itself does not change current obligations, so advisers remain exposed to compliance deficiencies under the existing rules until any final amendments become effective.
Key Points and Next Steps
The Proposed Rule would significantly narrow Form PF’s reach and roll back several of the most operationally demanding elements added or expanded in recent years, especially for smaller advisers, mid-sized hedge fund managers, and private equity advisers subject to event reporting. Advisers could see lower reporting costs, fewer event-driven escalation obligations, and potentially reduced examination exposure tied to Form PF triggers and data quality issues.
For now, however, advisers should treat the Proposed Rule as an important directional development—not a present compliance change—and continue to meet current Form PF obligations while reassessing implementation priorities, preparing comments, and monitoring whether the SEC and CFTC ultimately finalize a meaningful retreat from the 2023 and 2024 expansion of the form.
Your Alston & Bird team is prepared to help address any questions related to the SEC and CFTC’s proposed Form PF changes.
If you have any questions, or would like additional information, please contact one of the attorneys on our Investment Funds team.
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