On April 24, the SEC and CFTC jointly proposed amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, including those also registered with the CFTC as commodity pool operators or commodity trading advisors. Form PF collects information designed to facilitate FSOC’s monitoring of systemic risk and is used by the SEC and CFTC in their investor protection efforts. The proposal follows a “comprehensive review” conducted in accordance with a January 2025 presidential memorandum directing agencies to halt all new and recently issued rules pending review, which prompted the agencies to delay the compliance date for 2024 Form PF amendments multiple times, most recently to October 1, 2026. SEC Chairman Paul Atkins stated that “[p]rior amendments to Form PF have led to overly burdensome disclosure requirements for advisers, distracting them from their core investment functions, often without a commensurate benefit to regulators’ use of the collected data.”

The proposed amendments would, among other things:

1. Raise the filing threshold for all Form PF filers from $150 million to $1 billion in private fund assets under management, which the agencies estimate would eliminate filing obligations for nearly half of the advisers currently required to file while continuing to capture over 90 percent of private fund gross asset value
2. Raise the reporting threshold for “large” hedge fund advisers from $1.5 billion to $10 billion in hedge fund assets under management, eliminating certain reporting obligations for almost two-thirds of advisers currently filing as large hedge fund advisers while continuing to obtain quarterly information on over 80 percent of hedge fund gross asset value
3. Eliminate or streamline numerous existing requirements, including certain “look through” requirements, performance volatility reporting, portfolio turnover reporting, rehypothecation reporting, and the consolidated counterparty exposure table for qualifying hedge funds
4. Eliminate certain current reporting triggers for large hedge fund advisers, including reports for margin defaults and inability to satisfy redemption requests, and modify the filing deadline by removing the “as soon as practicable” requirement so advisers would have a full 72 hours to file
5. Eliminate quarterly event reporting for all private equity fund advisers
6. Enable a method to identify funds active in the private credit market

Comments on the proposal must be submitted by June 23.