SEC and CFTC Propose Major Form PF Overhaul: What Private Fund Managers Need to Know

If you manage a private fund, you've spent years building compliance infrastructure around Form PF, the confidential reporting form that the SEC and CFTC have used since 2012 to collect systemic risk data on private fund advisers. For many managers, especially emerging and mid-sized ones, Form PF has been one of the more burdensome regulatory obligations. Detailed exposure reporting, event-driven filings, look-through requirements for fund structures, and increasingly granular data demands have made it a consistent operational challenge.

On April 20, 2026, the SEC and CFTC jointly proposed changes that would substantially roll back those requirements. For roughly half of current Form PF filers, the proposal would eliminate the filing obligation entirely. For those who remain in scope, many of the most operationally demanding requirements would disappear or simplify significantly. The proposal is still in a 60-day comment period, so nothing is final. But the direction is clear, and fund managers should be paying close attention right now.

Key Takeaways

• The SEC and CFTC have proposed raising the Form PF filing threshold from $150 million to $1 billion in private fund assets under management (AUM), which would exempt nearly half of current filers
• The "large" hedge fund adviser threshold would rise from $1.5 billion to $10 billion
• Private equity advisers would no longer be required to file quarterly event reports
• Many detailed reporting requirements for large hedge fund advisers would be eliminated or simplified
• The proposal is open for public comment for 60 days after Federal Register publication
• Private credit funds may face enhanced reporting requirements under a separate proposal
  
  

The Headline Change: A Higher Filing Threshold

The most significant change is the proposed increase in the filing threshold. Today, any SEC-registered investment adviser with $150 million or more in private fund AUM must file Form PF. The proposal raises that threshold to $1 billion. That single change would remove nearly half of current filers while still capturing approximately 94% of total private fund assets. The agencies are effectively acknowledging a long-standing industry concern: smaller advisers have been bearing a disproportionate compliance burden relative to the systemic risk data they provide.

The shift is even more pronounced for hedge fund advisers. Currently, advisers with $1.5 billion or more in hedge fund AUM are classified as “large” and subject to enhanced reporting. The proposal raises that threshold to $10 billion, meaning roughly two-thirds of current large filers would fall out of that category. Those firms would still file Form PF if they remain above the $1 billion threshold, but without the most intensive reporting requirements. The agencies estimate that 81% of hedge fund assets would remain covered under the new framework.

For emerging managers in the $150 million to $1 billion range, this represents meaningful operational relief. For hedge fund advisers between $1.5 billion and $10 billion, it could eliminate some of the most time-consuming reporting obligations.

What's Being Streamlined for Large Hedge Fund Advisers

For advisers who still qualify as "large" hedge fund managers under the new $10 billion threshold, the proposal would eliminate or substantially simplify roughly ten existing reporting requirements.

The reporting requirements to be removed include performance volatility reporting, monthly exposure tracking, asset turnover reporting, and rehypothecation data. The agencies have determined this information either duplicates other data sources or doesn't provide the systemic risk insight it was designed to capture.

On timing, large hedge fund advisers who currently face immediate filing obligations for certain reports would get an extended window of 72 hours. That's a more workable standard for firms whose trading activity and positions change frequently.

What's Being Eliminated for Private Equity Advisers

For private equity (PE) fund advisers, the proposal removes one of the most administratively burdensome provisions in the current form: quarterly event reporting.

Right now, PE fund advisers are required to file current reports within 60 days of the end of any quarter in which certain events occur: adviser-led secondary transactions, general partner (GP) removals or clawbacks, terminations of the fund's investment period, and certain fund closures. The proposal would eliminate all of these quarterly event reporting requirements entirely.

That's not a minor administrative tweak. For PE advisers with active portfolios, these filings can trigger multiple times a year and require coordinated data collection from legal, finance, and operations teams. Removing them simplifies the compliance calendar and reduces the resources firms need to dedicate to ongoing monitoring.

In addition, look-through requirements for master-feeder fund structures would go away for both hedge funds and PE advisers. Currently, advisers must "look through" feeder funds to report consolidated exposure at the master fund level, a process that can get complicated quickly with layered fund structures. The proposal would permit reasonable estimates for indirect exposure reporting instead, removing the obligation to trace individual transaction flows.

Who Benefits Most, and Who Doesn't

Three groups stand to benefit most:

• Emerging and smaller managers between $150 million and $1 billion in AUM, who would exit Form PF entirely
• Mid-sized hedge fund advisers between $1.5 billion and $10 billion, who would no longer qualify as large filers
• Private equity advisers, who benefit from the elimination of quarterly event reporting

The largest managers, particularly those well above $10 billion, remain fully subject to detailed reporting. The agencies have made clear that systemic risk oversight will remain focused on firms with the potential to impact markets.

One area to watch is private credit. The proposal requests comments on whether additional reporting requirements should apply to private credit funds. Given the growth of the asset class, this could become a focal point of future regulation.

What Managers Should Do Now

The comment period closes 60 days after publication in the Federal Register. Managers with strong views on the proposal, particularly around thresholds or private credit, should consider submitting comments directly or through industry groups. Beyond that, three practical steps stand out:

1. Assess Your Position Relative to the New Thresholds. If you would fall below the $1 billion threshold, begin evaluating what that means for your compliance structure. No changes should be made yet, but early planning will allow you to act deliberately if the rule is finalized.
2. Identify Where the Operational Burden Actually Sits. Not all changes will affect every firm equally. Focus on the requirements that currently consume the most time and resources.
3. Maintain Discipline Around Infrastructure. Reduced regulatory requirements do not eliminate the need for strong operational infrastructure. Investor expectations, due diligence standards, and internal reporting requirements remain unchanged. Firms that scale back too aggressively often find themselves rebuilding under pressure when investor scrutiny increases.
   
   

The Bigger Picture

This proposal reflects a broader regulatory shift toward reducing compliance costs, particularly for smaller and mid-sized advisers. But regulatory environments are cyclical. Requirements that are relaxed under one administration can return under another, often with added complexity.

The firms best positioned for long-term success are those that build infrastructure based on operational needs and investor expectations, not just regulatory minimums.

The proposed changes create breathing room; how that time is used will matter.

How Stable Rock Can Help

If you are evaluating how these changes affect your compliance calendar or operating model, it's worth discussing with an adviser before the rules are finalized.

Stable Rock works with investment managers on compliance infrastructure, reporting, and operational readiness, helping firms adapt to regulatory change while maintaining strong internal processes. Reach out to our team to learn more.