SEC and CFTC Propose Targeted Changes to Form PF Reporting Framework

The SEC and CFTC have jointly proposed amendments to Form PF that would meaningfully reduce reporting obligations for many private fund advisers while preserving the core data set used for systemic risk monitoring.

The proposal reflects a measured recalibration rather than a fundamental shift in approach. Form PF has always served an important function for both FSOC and the agencies, and that underlying purpose remains intact. What is changing is the scope of who reports and how much detail is required.

Higher Thresholds, Fewer Filers

The most significant change is the proposed increase to the Form PF filing threshold. Advisers would not be required to file unless they manage at least $1 billion in private fund assets, up from the current $150 million threshold.

That is a substantial move. It would remove a large portion of smaller and mid-sized advisers from the reporting regime altogether, even though those firms collectively represent a meaningful segment of the market. The agencies note that, despite this shift, Form PF would still capture over 90 percent of private fund gross assets, which helps explain the policy rationale.

Still, the $1 billion threshold is not a minor adjustment. It reflects a judgment that systemic risk monitoring is best served by focusing on larger managers, but it also means less visibility into a broad swath of the market that may, in aggregate, present risks worth understanding.

Redefining “Large” Hedge Fund Advisers

The proposal also raises the bar for enhanced reporting by large hedge fund advisers. The threshold would increase from $1.5 billion to $10 billion in hedge fund assets under management.

For advisers below that level, the practical effect is a meaningful reduction in reporting complexity. For those above it, detailed reporting remains in place, consistent with the agencies’ focus on scale and potential market impact.

Streamlining the Form

In addition to the threshold changes, the proposal would eliminate or simplify a number of existing reporting requirements. The agencies are clearly looking to reduce duplicative or lower-value data fields and to streamline the overall filing process.

For clients, this is where the day-to-day benefit is likely to be most tangible. Even for advisers that remain subject to Form PF, a more focused form should translate into less operational friction and fewer bespoke compliance processes.

Continued Focus on Private Credit

One notable addition is the effort to better identify funds with exposure to private credit strategies. This is consistent with broader regulatory attention on that segment of the market.

While framed as an identification mechanism rather than an expansion of reporting, it is a reminder that the agencies are continuing to refine where they direct their focus, even as they reduce burdens elsewhere.

Practical Takeaways

From a client perspective, the proposal is generally favorable on the compliance side. Many advisers will fall out of scope entirely, and those that remain subject to Form PF should see a more streamlined reporting process.

At the same time, the increase to a $1 billion threshold raises a reasonable question about the level of visibility regulators will have into mid-sized advisers and the broader market. The agencies appear comfortable that the remaining coverage is sufficient, but it is an area that may draw comment.

The proposal is open for public comment for 60 days following publication in the Federal Register. Advisers should consider whether the proposed thresholds and reporting changes appropriately balance burden reduction with the continued utility of the data collected.

Overall, this is a pragmatic adjustment that reduces friction for advisers while keeping the core structure of Form PF in place.

That’s all for now,

Braeden