The Form PF reporting landscape has changed substantially over the last several years as regulators have sought to balance effective oversight with reporting efficiency. These reforms have included both expanded reporting requirements and more recent measures designed to reduce compliance burdens by increasing reporting thresholds and narrowing certain obligations.

The past few years have seen significant changes to the Form PF reporting regime. In 2023, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) (together, the "Commissions") introduced reporting requirements for certain event-driven occurrences.

This was followed in 2024 by a comprehensive package of amendments that significantly expanded reporting obligations across the Form PF report. The implementation of these amendments has not been straightforward. The compliance date has been delayed on several occasions, most recently to 1 October 2026, as private fund advisers continue to assess the operational challenges associated with the revised requirements.

In April 2026, the SEC and CFTC responded to these concerns by proposing a further set of amendments designed to streamline reporting requirements and make technical corrections to the form. While the proposals do not represent a complete reversal of the 2024 reforms, they signal a notable shift towards a more proportionate reporting regime.

In this article, we examine the most significant proposed changes, highlighting how they differ from the 2024 amendments and the existing Form PF reporting regime, and assess their implications for private fund advisers.

Higher reporting thresholds

The most consequential aspect of the proposals for many private fund advisers is the substantial increase in Form PF filing thresholds.

The Commissions have proposed raising the minimum reporting threshold for all Form PF filers from $150 million in regulatory assets under management to $1 billion. In addition, the threshold for large hedge fund advisers would increase from $1.5 billion to $10 billion.

According to the SEC, this would reduce the overall number of advisers required to submit the form by approximately 43%. However, the regulator notes that due to the size of the businesses in scope, it would continue to receive information covering more than 90% of the private fund gross asset value currently reported.

Similarly, the increase in the large hedge fund adviser threshold would result in approximately 65% fewer advisers being subject to the enhanced reporting requirements applicable through section 2 of the Form PF return.

The proposals reflect the Commissions view that reporting requirements should remain focused on the largest market participants while reducing compliance burdens for smaller advisers that are less likely to present systemic risk concerns.

Proposed elimination of certain reporting requirements

A key objective of the proposed amendments is the removal of reporting requirements that have proven difficult to implement or that regulators no longer consider necessary to the underlying purpose of the form. The most notable eliminations are:

• The removal of certain trading and clearing reporting requirements. This includes the obligation to report the value of positions at the end of the reporting period.

• The removal of monthly asset turnover reporting. Under the current Form PF, turnover reporting is contained within Question 27 and was due to be expanded through the 2024 amendments with the revised Question 34 which includes additional asset classes.

• The elimination of Question 23(c). A requirement introduced by the 2024 amendments that requires advisers to report detailed volatility information relating to fund portfolios.

• The removal of rehypothecation reporting requirements. The Commissions acknowledge that obtaining this information remains operationally challenging for many advisers. As a result, existing Question 38 and revised Question 45 under the 2024 amendments would be removed.

• The removal of Questions 39 and 40. These currently require large hedge fund advisers to report detailed information regarding monthly exposure to reference assets.

Collectively, these changes will significantly reduce the volume of data required to be collected, validated, and reported by advisers, actively supporting the Commissions attempt to shift to a more proportionate regime.

Changes to current reporting requirements

The Commissions have also proposed important revisions to Section 5 of the Form PF return. This section requires large hedge fund advisers to submit reports upon the occurrence of a specified trigger event.

One of the key clarifications is the removal of the requirement to file reports "as soon as practicable". Instead, advisers would be afforded the full 72-hour reporting period following the occurrence of a reportable event, creating greater certainty around filing expectations.

Additional proposed changes to current reporting include:

• Removing the notice required in respect of a margin default or determining the inability to meet a call for margin, collateral or equivalents (Item D).

• Narrowing the definition of an "operational event" under Item G.

• Removing the requirement to file a current report where a qualifying hedge fund is unable to satisfy a redemption request (Item I).

The proposals would also eliminate the quarterly event reporting requirements introduced for private equity fund advisers under Section 6 of Form PF.

These amendments represent a meaningful reduction in event-driven reporting obligations and should simplify compliance procedures for affected firms.

Relief for master-feeder structures

The treatment of feeder funds was another area that generated industry concern following the publication of the 2024 amendments. Under the existing Form PF framework, advisers have the flexibility to aggregate master-feeder arrangements for reporting purposes. Under the 2024 amendments, feeder funds could only be disregarded for reporting purposes if they held no assets other than interests in the master fund, U.S. Treasury bills and cash equivalents.

Under the latest proposals, advisers would be able to disregard feeder funds where no more than 5% of gross asset value is invested in other assets, providing greater flexibility for master-feeder arrangements.

This change recognises the practical realities of many fund structures and would help alleviate reporting burdens for advisers operating complex master-feeder arrangements.

Increased focus on private credit

While many of the proposals seek to reduce reporting obligations, the Commissions are simultaneously signalling increased interest in private credit markets.

The private credit sector has grown substantially since Form PF was first introduced in 2011. Currently, private credit fund advisers follow the same general instructions as other private fund advisers when determining which sections of Form PF to be completed.

Recognising the continuing growth and evolving risk profile of the sector, the Commissions have requested industry feedback on a number of private credit-related issues, including:

• Whether a dedicated reporting section should be introduced for private credit funds.

• What specific data should be collected from private credit advisers.

• Which risks associated with private credit markets are most relevant from a regulatory and systemic risk perspective.

Although no specific reporting framework has yet been proposed, the consultation demonstrates that private credit remains a key area of supervisory focus and may be subject to more targeted reporting requirements in the future.

What happens next?

The consultation period for the proposed amendments closed on 23 June 2026. The Commissions have stated that any final rules will be subject to a minimum 12-month transition period and that they will consider the interaction with the 2024 amendments, which currently have a compliance date of 1 October 2026.

Overall, the proposals represent a considerable reduction in reporting obligations when compared with the 2024 amendments. The proposed increase in reporting thresholds alone would remove Form PF obligations for a significant number of smaller private fund advisers while preserving the regulators' visibility over the vast majority of private fund assets.

For firms that have spent the last two years preparing for the expansive 2024 amendments, the latest developments provide a welcome opportunity to reassess implementation plans and monitor the direction of travel of the Form PF regime.

While uncertainty remains until the final rules are adopted, the proposals suggest that the Commissions are seeking a more proportionate balance between regulatory oversight and the operational burden placed on private fund advisers. Our experienced regulatory reporting team can help you navigate the proposed Form PF amendments and assess their impact on your reporting framework. To discuss your specific circumstances and compliance obligations, please get in touch to arrange a call.