On April 20, 2026, the CFTC and SEC released a joint proposal (Release No. 9216-26) aimed at “rationalizing” the reporting requirements for private fund managers. By significantly narrowing the scope of Form PF, regulators are signaling a transition toward a more targeted approach to systemic risk monitoring.
Why are the SEC and CFTC proposing changes to Form PF now?
The 2026 amendments are designed to eliminate regulatory redundancy and reduce the high costs associated with compliance for smaller and mid-sized fund managers. Regorters have found that current reporting thresholds were capturing a large volume of firms that do not pose a systemic risk to the U.S. financial system, leading to unnecessary administrative burdens.
What are the new AUM thresholds for Form PF reporting?
The proposal introduces a massive shift in who is required to file:
- The Baseline Threshold: The entry point for filing Form PF would jump from $150 million to $1 billion in assets under management.
- The “Large Hedge Fund” Threshold: The definition of a large hedge fund adviser would increase nearly seven-fold, moving from $1.5 billion to $10 billion in AUM.
Which investment advisers benefit most from this proposal?
The biggest beneficiaries are small and mid-sized hedge fund and private equity managers. Under the new rules, nearly 50% of currently registered advisers would be completely exempt from Form PF filing. Additionally, many firms that remain subject to the rules would see their reporting frequency reduced from quarterly to annually.
How will regulators monitor the Private Credit market under these rules?
Rather than applying a broad reporting requirement to all firms, the proposal introduces specific identifying questions to isolate funds participating in private credit and direct lending. This allows the SEC and CFTC to gather intelligence on “shadow banking” risks without imposing the full weight of Form PF on firms that do not engage in these activities.
Does the 2026 Form PF proposal weaken market oversight?
Regulators argue that oversight remains robust because the remaining filers still represent the vast majority of market activity. Even with fewer firms filing, the agencies will continue to track approximately 90% of all private fund assets and 80% of hedge fund assets, focusing their resources on the largest institutional players where systemic risk is most likely to originate.
When do the new Form PF rules go into effect?
As of April 2026, these changes are in the notice-and-comment phase. The public has 60 days to provide feedback via the SEC or CFTC websites. If adopted, a transition period is expected to follow, though the agencies have expressed an interest in implementing the higher thresholds as soon as possible to provide immediate relief to smaller firms.
Quick Comparison: Proposed Disclosure Relief
| Reporting Requirement | Old Standard (Pre-2026) | New Proposed Standard |
| Small Adviser Filing | Required at $150M AUM | Exempt under $1B AUM |
| Large Hedge Fund Designation | $1.5B AUM | $10B AUM |
| Reporting Frequency | Quarterly for many | Primarily Annual |
Disclaimer: This summary is provided for educational purposes and is not intended as legal or regulatory advice. Always consult with legal counsel regarding specific SEC and CFTC filing obligations.