Form PF has been a compliance burden for private fund advisers since its introduction following the Dodd-Frank Act, and that burden grew significantly with the amendments adopted in 2023 and 2024 under the prior Commission. On April 20, 2026, the SEC and CFTC proposed walking a meaningful portion of that back.
The joint proposal doesn’t eliminate Form PF. It raises filing thresholds, removes several reporting requirements the current Commission views as disproportionate to their regulatory utility, and explicitly signals a shift in philosophy: disclosure obligations should be calibrated to the information regulators actually use, not to the maximum amount of information that could theoretically be collected.
For private fund advisers currently filing Form PF, the proposal creates a genuine compliance planning question, not just whether obligations are changing, but how to position the program for what the final rule is likely to require. Here’s what the proposal actually says and where the operational implications land.
The Filing Threshold Change: Who Gets Out
The most significant change in the proposal is the filing threshold increase for smaller advisers. Currently, any SEC-registered investment adviser with at least $150 million in private fund assets under management is required to file Form PF. The proposal would raise that threshold to $1 billion.
The practical consequence is substantial. The SEC estimates that smaller advisers, those below the proposed $1 billion threshold, represent almost half of all advisers currently required to file. If the proposal is adopted as written, roughly half of today’s Form PF filers would no longer have a filing obligation at all.
For advisers in that range, the threshold change isn’t just a paperwork reduction. Form PF compliance has required dedicated resources, data aggregation, internal review processes, and quarterly or annual filing cycles depending on fund type. Firms that built compliance infrastructure specifically around Form PF obligations will need to evaluate which of those processes remain necessary for other regulatory purposes and which were Form PF-specific.
The $1 billion threshold applies to private fund assets under management in aggregate, not to individual fund size. Advisers managing multiple smaller funds whose combined private fund AUM approaches the threshold should track the number carefully, the proposal is still pending and the final threshold could shift based on public comment.
The Large Hedge Fund Adviser Threshold: Less Scrutiny at the Top
The proposal also raises the reporting threshold for “large” hedge fund advisers, those subject to the more detailed exposure reporting requirements under Section 2 of Form PF. Currently, the large hedge fund adviser designation applies at $1.5 billion in hedge fund assets under management. The proposal raises that to $10 billion.
This is a significant change for mid-sized hedge fund managers. Advisers between $1.5 billion and $10 billion in hedge fund AUM currently face substantially more detailed quarterly filing requirements than their smaller peers, including granular position-level data on exposure, leverage, and liquidity. Under the proposal, those advisers would no longer be subject to Section 2 requirements, they’d file under the less burdensome general reporting framework instead.
The rationale from both Chairmen was explicit: the prior amendments created reporting requirements for this tier of adviser that generated data regulators found limited practical use for in systemic risk monitoring, while consuming significant compliance resources at the fund level. The proposal recalibrates accordingly.
What’s Being Eliminated and Streamlined
Beyond the threshold changes, the proposal would eliminate or streamline a number of specific Form PF requirements that were added or expanded in the 2023 and 2024 amendments. The proposing release details the specific line items, but the categories of reduction fall into three areas.
Current reporting events. The 2023 amendments introduced current reporting requirements, accelerated filings triggered by specific events at large hedge funds and private equity funds, including certain extraordinary investment losses, significant margin or counterparty default events, and material changes in prime broker relationships. The current Commission has signaled that several of these triggers were set too broadly, generating filings for events that didn’t represent the kind of systemic risk the form was designed to monitor.
Exposure and investment data. Several granular exposure and portfolio data fields required under the current form are proposed for elimination or simplification, on the basis that the data collected wasn’t being meaningfully used in systemic risk analysis and imposed disproportionate operational burden to compile accurately.
Private credit identification. The proposal adds one new element: a method to identify funds active in the private credit market. This is additive, not reductive, it reflects the SEC and CFTC’s interest in building better visibility into the private credit sector, which has grown substantially and sits outside some of the existing reporting frameworks.
What Doesn’t Change
The proposal is explicit that Form PF continues to collect information on over 90 percent of private fund gross assets. The systemic risk monitoring function that Form PF was designed to serve, giving FSOC the data it needs to evaluate risks to financial stability, isn’t being dismantled. It’s being recalibrated.
Large hedge fund advisers above the new $10 billion threshold still face detailed reporting requirements. Private equity fund advisers above the filing threshold still file annually. The fundamental architecture of the form, confidential filing, systemic risk focus, FSOC data sharing, remains intact.
The change is in the calibration: fewer filers, less granular data requirements for the advisers who do file, and an explicit acknowledgment that the prior amendments had drifted away from the form’s original purpose.
The Comment Period and What Happens Next
The proposal is subject to a 60-day public comment period following publication in the Federal Register. Both Chairmen explicitly invited comment, and the CFTC’s statement in particular flagged interest in public input before finalizing the changes.
For private fund advisers, the comment period creates a specific opportunity. Advisers who have found particular Form PF requirements burdensome, whether specific data fields, current reporting triggers, or definitional ambiguities that complicated accurate filing, have 60 days to say so on the record. The current Commission’s stated posture is to reduce compliance burden where the regulatory benefit doesn’t justify it. Comments that document specific operational costs tied to specific requirements are likely to receive genuine consideration.
The proposal doesn’t have a stated effective date. Given the 60-day comment period and the typical timeline for finalizing proposed rules, advisers should plan for the final rule to arrive sometime in late 2026 at the earliest, though it could extend into 2027 depending on the volume and complexity of comments received.
What This Means for Compliance Programs Right Now
The proposal is not a final rule. Nothing in the current Form PF obligations changes until a final rule is adopted and effective. Advisers currently required to file Form PF should continue filing on their current schedules and to current requirements.
What the proposal does change is the planning horizon.
Advisers near the current $150 million threshold who expect to remain below $1 billion when a final rule is adopted should begin evaluating what their Form PF compliance infrastructure looks like if the filing obligation goes away. Some of that infrastructure, data aggregation processes, internal review cycles, vendor relationships built around Form PF data, may be partially or fully reducible. Identifying those dependencies now, before the rule is final, means the transition is orderly rather than reactive.
Advisers in the $1.5 billion to $10 billion hedge fund AUM range face a different planning question: if the large hedge fund adviser designation is raised to $10 billion, their quarterly filing cadence and Section 2 reporting requirements change significantly. The simpler annual filing framework that would apply carries different data requirements and different timelines. Compliance programs built around the current quarterly rhythm will need to be reconfigured.
For advisers that file as commodity pool operators or commodity trading advisors with the CFTC in addition to their SEC registration, the population the joint proposal is specifically designed to address, the threshold and streamlining changes apply to both agencies’ requirements simultaneously. Dual registrants who have been navigating the intersection of SEC and CFTC Form PF obligations since the 2023 amendments should track the joint rulemaking closely, as the final rule will govern both filing obligations in one place.
The Broader Signal
The Form PF proposal is the third significant action from the current SEC and CFTC in April 2026 alone, following the crypto asset taxonomy clarification and the joint MOU on coordinated examinations. Taken together, they reflect a Commission that is actively recalibrating the regulatory framework it inherited, reducing compliance burden in areas where it views the prior Commission as having overreached, while increasing coordination and scrutiny in areas where it sees gaps.
For private fund advisers, the Form PF proposal is unambiguously positive news. It reduces obligations for roughly half of current filers, lightens the load for mid-sized hedge fund managers, and signals that the current Commission is willing to revisit the 2023 and 2024 amendments that created significant compliance strain.
The practical job for advisers right now is to understand exactly where their firm sits relative to the proposed thresholds, identify which specific requirements would change under the proposal, and begin the planning work that will make the transition clean when a final rule arrives.
The proposal is an opportunity. Whether it becomes relief or just another compliance event to manage depends on when that planning starts.
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