On April 20, 2026, the Securities and Exchange Commission (SEC) and U.S. Commodity Futures Trading Commission (CFTC) jointly proposed amendments to Form PF that would significantly reduce reporting obligations for many private fund advisers while seeking to preserve regulators’ ability to monitor risk in the private fund space. The proposal reflects a shift away from recent expansions of Form PF toward a more efficient and targeted reporting framework.
Form PF is a confidential reporting form filed by certain SEC-registered investment advisers to private funds, including those also registered with the CFTC as commodity pool operators or commodity trading advisors. The data collected from Form PF is used by the SEC, CFTC, and the Financial Stability Oversight Council (FSOC) to assess systemic market risk and inform regulatory oversight. Over time, Form PF has become a substantial compliance obligation, particularly for mid-sized registered investment advisers currently subject to filing Form PF solely due to exceeding the $150 million assets under management threshold.
The proposal would raise the minimum reporting threshold from $150 million to $1 billion in private fund assets under management. If adopted, this change would eliminate Form PF filing requirements for a significant portion of current filing advisers. Advisers below the new threshold would no longer be required to file, though they would remain subject to other regulatory obligations, including Form ADV and applicable investor disclosure requirements.
The proposal would also increase the threshold for “large hedge fund advisers” from $1.5 billion to $10 billion in hedge fund assets under management. As a result, fewer advisers would be subject to enhanced reporting requirements relating to exposures, leverage, and liquidity. Advisers above the revised threshold would continue to be required to provide detailed information, consistent with the agencies’ focus on systemically significant market participants.
In addition to the reporting threshold changes, the proposal would also eliminate or streamline a number of reporting requirements that have been widely viewed as operationally burdensome and of limited regulatory utility. At the same time, the proposal includes a mechanism to better identify funds active in the private credit market, indicating continued regulatory interest in that sector.
For advisers between $150 million and $1 billion in private fund assets under management, the proposal could remove a meaningful compliance burden. Firms that have invested in Form PF-related systems and processes may ultimately be able to simplify those frameworks. However, advisers should not make changes to existing compliance programs unless and until the amendments are finalized. Larger advisers are less likely to see a material reduction in obligations, though some reporting requirements may be refined.
The proposal also has implications for companies operating in the fintech and financial services sectors, particularly those that provide data aggregation, analytics, or compliance solutions to private fund advisers. Reduced reporting requirements may affect demand for certain Form PF-specific tools, while creating opportunities for more targeted data solutions, particularly in areas such as private credit.
Notably, the proposal is also the latest in the SEC’s and CFTC’s efforts at regulatory harmonization that began with the March 11, 2026 Memorandum of Understanding and the March 17, 2026 Joint Crypto Interpretation. The proposal is an important signal to the industry that both agencies are taking steps to reduce the regulatory burden on industry participants while preserving their respective agency’s ability to effectively regulate. The industry should expect continued dialogue around this and future joint proposals from the SEC and CFTC.
The proposal will be subject to a 60-day public comment period following publication in the Federal Register.
For more information, please contact Michael McDonald, Alice Cao, or any other member of Wilson Sonsini’s Fintech and Financial Services practice.
