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Form PF Overhaul: What Private Fund Advisers Need to Know
Gabriela Guevara | 27 May 2026
The SEC and CFTC’s April 20, 2026 joint proposal to amend Form PF marks one of the most significant shifts in private fund reporting since the form was adopted in 2011. The proposal would largely unwind the 2024 amendments, which were delayed several times between January 2025 and September 2025, most recently to October 1, 2026, before they take effect. With comments due June 23, 2026, and a minimum 12-month transition period anticipated, compliance teams should understand what is changing, what is not, and where uncertainty remains.
The proposal’s most immediate impact would be on smaller and mid-size advisers. The general filing threshold would rise from $150 million to $1 billion in private fund AUM, removing nearly half of current filers. Advisers below that threshold would still report private fund information on Form ADV, as applicable. The large hedge fund adviser threshold would increase from $1.5 billion to $10 billion, shifting roughly two-thirds of current large hedge fund advisers to annual filing and out of Section 5 current reporting. For private equity fund advisers, Section 6 quarterly event reporting (covering adviser-led secondaries, GP removals, investment period terminations, and fund terminations) would be eliminated entirely. Granular questions on monthly asset turnover, reference asset exposure, and rehypothecation would be removed or simplified, and prescriptive look-through requirements for indirect exposures would be replaced with a reasonable-estimates standard.
Not all obligations are being unwound. The large private equity fund adviser threshold ($2 billion) and large liquidity fund adviser threshold ($1 billion) remain unchanged. Advisers retaining large hedge fund status under the new $10 billion threshold would still face a 72-hour current reporting deadline, revised trading and clearing requirements, and counterparty exposure reporting, with fewer triggers but meaningful obligations. Master-feeder reporting would shift toward separate fund-level reporting for component funds, subject to a new 5% gross asset value exception for disregarded feeder funds. Advisers with complex fund structures, trading vehicles, or financing arrangements should not assume the proposal eliminates their reporting complexity.
Two significant open questions remain. First, on private credit: the agencies have not proposed a dedicated framework but have invited comment on whether one should be created, signaling that targeted private credit reporting remains a regulatory priority and that relief for private credit advisers may be limited. Second, on timing: the minimum 12-month transition period intersects with the pending October 1, 2026 compliance date for the 2024 amendments in a way the agencies have not yet resolved, though guidance consistent with past practice is anticipated. The proposal may also have implications for CFTC Letter No. 25-50, which conditions certain no-action relief on Form PF filing status. Advisers falling below the proposed $1 billion threshold may need further regulatory clarification regarding continued eligibility for that relief.
The April 2026 proposal represents a meaningful recalibration of Form PF, offering significant relief to smaller advisers, mid-size hedge fund managers, and private equity fund advisers alike. It is not a full retreat. Obligations remain for those still in scope, and open questions around private credit and transition timing require continued monitoring. We will track rulemaking developments and provide updated guidance as this process unfolds. Comments to the SEC are due June 23, 2026.
What is Being Rolled Back or Eliminated
The proposal’s most immediate impact would be on smaller and mid-size advisers. The general filing threshold would rise from $150 million to $1 billion in private fund AUM, removing nearly half of current filers. Advisers below that threshold would still report private fund information on Form ADV, as applicable. The large hedge fund adviser threshold would increase from $1.5 billion to $10 billion, shifting roughly two-thirds of current large hedge fund advisers to annual filing and out of Section 5 current reporting. For private equity fund advisers, Section 6 quarterly event reporting (covering adviser-led secondaries, GP removals, investment period terminations, and fund terminations) would be eliminated entirely. Granular questions on monthly asset turnover, reference asset exposure, and rehypothecation would be removed or simplified, and prescriptive look-through requirements for indirect exposures would be replaced with a reasonable-estimates standard.
What is Staying in Place or Still Being Introduced
Not all obligations are being unwound. The large private equity fund adviser threshold ($2 billion) and large liquidity fund adviser threshold ($1 billion) remain unchanged. Advisers retaining large hedge fund status under the new $10 billion threshold would still face a 72-hour current reporting deadline, revised trading and clearing requirements, and counterparty exposure reporting, with fewer triggers but meaningful obligations. Master-feeder reporting would shift toward separate fund-level reporting for component funds, subject to a new 5% gross asset value exception for disregarded feeder funds. Advisers with complex fund structures, trading vehicles, or financing arrangements should not assume the proposal eliminates their reporting complexity.
What Remains Uncertain
Two significant open questions remain. First, on private credit: the agencies have not proposed a dedicated framework but have invited comment on whether one should be created, signaling that targeted private credit reporting remains a regulatory priority and that relief for private credit advisers may be limited. Second, on timing: the minimum 12-month transition period intersects with the pending October 1, 2026 compliance date for the 2024 amendments in a way the agencies have not yet resolved, though guidance consistent with past practice is anticipated. The proposal may also have implications for CFTC Letter No. 25-50, which conditions certain no-action relief on Form PF filing status. Advisers falling below the proposed $1 billion threshold may need further regulatory clarification regarding continued eligibility for that relief.
Key Takeaways
The April 2026 proposal represents a meaningful recalibration of Form PF, offering significant relief to smaller advisers, mid-size hedge fund managers, and private equity fund advisers alike. It is not a full retreat. Obligations remain for those still in scope, and open questions around private credit and transition timing require continued monitoring. We will track rulemaking developments and provide updated guidance as this process unfolds. Comments to the SEC are due June 23, 2026.