SEC Proposes Rule to Reduce Form PF Filing

April 20, 2026

What happened?

On April 20, 2026, the SEC and CFTC jointly proposed amendments to Form PF that would drastically reduce both the number of filers and the specific requirements for reporting that have expanded through prior amendments. We have seen the compliance date for the 2024 amendments to Form PF extended multiple times, including after a Presidential Memorandum for agencies to review rules that had not yet taken effect.  Here, the agency review has led to a new proposal that would reduce reporting and the associated compliance costs.

In the press release, Chairman Atkins said, “[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. These proposed changes would help to rationalize the scope of Form PF requirements to support its purpose and bring our overall disclosure regime back into alignment.”

The proposed amendments would:

• Raise the current Form PF filing threshold from $150 million in private fund assets managed by a firm and its related persons to $1 billion.
• Raise the large hedge fund reporting threshold from $1.5 billion to $10 billion, eliminating the need for those below the threshold to provide the enhanced reporting on the current Form PF.
• Shrink other required reporting including “eliminating certain “look through” requirements; eliminating certain performance volatility reporting requirements; simplifying certain large hedge fund counterparty exposure reporting; eliminating certain current reporting for large hedge fund advisers; eliminating quarterly event reporting for all private equity fund advisers” along with other revisions.

The proposed transition period would be 12 months from adoption and publication in the Federal Register. However, the SEC and CFTC indicated that they are mindful of the current October 1, 2026, deadline for the 2024 amendments and its relation to the ultimate timing of the proposed amendments. Public comments on whether the transition period should be shortened to 6 months or extended to 12 were requested.  The proposal is open for public comment for 60 days, and public comments may be posted here.

What does this mean for me?

The pendulum is swinging toward deregulation. After a regulatory freeze and instructions to review rules at the start of the new administration, we now have a proposal that would drastically change Form PF. Less data would need to be collected and reported, and fewer firms would have to complete the confidential filing.

This confidential information is used by the SEC and CFTC in their investor protection efforts. With a new proposal from the DOL to invite 401k plan investment in alternative assets like private equity, a wider variety of investors may soon need this protection. If so, there may be future pressure for the pendulum to swing back from reduced reporting to enhanced reporting, again.

We will continue to monitor regulatory updates and new developments that impact investment advisors. If you have questions, contact us. Fairview is here to help.