On April 20, 2026, the Securities and Exchange Commission and the Commodity Futures Trading Commission proposed amendments that would materially reduce reporting obligations for many private fund advisers. The proposed amendments to Form Private Fund (PF) are framed as a broad review of the form, with the agencies saying they want to eliminate certain burdens while continuing to collect information that is necessary and appropriate in the public interest and for the protection of investors or for the assessment of systemic risk by the Financial Stability Oversight Council. A related fact sheet was also published.
Form PF was amended in 2024 to require more detailed reporting. According to the fact sheet, developments following those amendments, including a Presidential Memorandum and feedback from market participants, led the agencies to extend the compliance date for those requirements to Oct.1, 2026, so they could complete a further review and consider additional action.
What’s Changing and Why it Matters to Advisers
The proposed amendments would increase the threshold for all Form PF filers from $150 million in private fund assets under management to $1 billion. That would remove filing obligations for many advisers that currently must submit Form PF, while the agencies would still obtain data on a significant portion of private fund gross asset value.
The proposal would also raise the reporting threshold for large hedge fund advisers from $1.5 billion in hedge fund assets under management to $10 billion. This change eliminates certain reporting obligations for many advisors that report as large hedge fund advisors while the agencies would still obtain information from a substantial portion of hedge fund gross asset value.
Beyond the threshold changes, the proposal includes a broader simplification of reporting requirements.
Among other things, the Commissions would eliminate certain “look-through” requirements, remove certain performance volatility reporting requirements, simplify large hedge fund counterparty exposure reporting, eliminate some current reporting for large hedge fund advisers, and eliminate quarterly event reporting for all private equity fund advisers. In addition, the proposed amendments to Form PF would enable the identification of funds active in the private credit market. The fact sheet also notes that the proposal includes corrections and other revisions to the form.
The proposed release will be published in the Federal Register, and the comment period will remain open for 60 days after publication.
Prepare for Change: Key Steps for Advisers
For advisers, the practical message is that Form PF may become narrower and easier to administer, especially for firms below the new thresholds. If adopted as proposed, the amendments could reduce the number of advisers subject to filing, lower the data requirements for certain hedge fund advisers, and simplify several recurring reporting processes, while leaving the largest private fund and hedge fund advisers within scope for reporting.
Advisers that currently file Form PF or that may come close to the new thresholds should monitor the rulemaking closely, assess the impact on internal data collection, and be prepared to adjust compliance workflows if the amendments are adopted.
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Frequently Asked Questions
The proposal is designed to reduce reporting burdens for private fund advisers while preserving the agencies’ ability to collect information that supports investor protection and systemic risk oversight. In practical terms, the agencies are trying to simplify the form and limit filing obligations for advisers that are not among the largest firms.
Smaller and mid-sized private fund advisers would likely see the most relief, because the proposal would raise the Form PF filing threshold for all filers from $150 million to $1 billion in private fund assets under management. Large hedge fund advisers would also be affected, since the reporting threshold for that category would increase from $1.5 billion to $10 billion in hedge fund assets under management.
The proposal would eliminate certain look-through requirements, remove performance volatility reporting, simplify counterparty exposure reporting for large hedge fund advisers, eliminate some current reporting for those advisers, and end quarterly event reporting for all private equity fund advisers. The overall effect would be a narrower and less burdensome Form PF framework if the proposal is adopted.
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