On April 20, 2026, the Securities and Exchange Commission and the Commodity Futures Trading Commission jointly proposed amendments that would significantly narrow the scope of Form PF. The proposal is intended to reduce recent expansions that result in overly burdensome reporting requirements and partially unwinds the Biden administration’s 2024 Form PF amendments.
Most notably, the proposal would increase the filing threshold from $150 million to $1 billion in private fund assets under management, a change that would eliminate Form PF obligations for nearly half of current filers. In addition, the threshold for large hedge fund advisers, a designation requiring quarterly reporting and enhanced filing requirements, would rise from $1.5 billion to $10 billion in hedge fund assets.
For advisers that remain subject to Form PF, the proposal would eliminate or scale back several requirements viewed as duplicative or of limited value. Key changes include the following:
- Elimination of quarterly event reporting for private equity fund advisers (such as GP removals, secondary transactions, and fund terminations)
- Removal of certain volatility calculations introduced in the 2024 rules
- Elimination of “look‑through” reporting for indirect exposures and de minimis feeder fund interests
- Reduced identification requirements for trading vehicles
- Elimination of margin default event and collateral reporting for large hedge fund advisers
The proposal sets a 60‑day public comment period and a 12‑month transition period following adoption. While enhanced Form PF reporting adopted in 2024 is currently scheduled to take effect on October 1, 2026, the agencies indicated they will consider how any final amendments align with that compliance date.
The proposed regulation is available here and a related press release is available here. Should you have any questions, please contact Joseph M. Mannon at jmannon@vedder.com, Cody J. Vitello at cvitello@vedder.com, Adam S. Goldman at agoldman@vedder.com, Jeff VonDruska at jvondruska@vedder.com, David W. Soden at dsoden@vedder.com, or the Vedder lawyer(s) with whom you normally work.
