April 28, 2026
Proposed changes may mean reduced reporting burden and higher reporting thresholds for registered investment advisers
By Christina McGlosson
The Securities Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly proposed amendments to Form PF, the confidential reporting form that certain SEC-registered investment advisers, including those that also are registered with the CFTC as a commodity pool operator or a commodity trading advisor, use to report information about the private funds they advise. The public comment period on the proposed rule concludes on June 19, 2026.
Form PF collects information designed to facilitate the Financial Stability Oversight Council’s (FSOC) monitoring of systemic risk in the financial markets. The SEC and CFTC also use the information collected on Form PF in their investor protection efforts.
Among the goals of the amendments are raising the filing threshold, thereby reducing the burdens of filing on funds with lower assets under management (AUM), and streamlining Form PF.
Purpose of Form PF
Investment advisers that are registered both under the SEC’s Investor Advisers Act of 1940, and the CFTC’s Commodity Exchange Act must maintain records and reports for each private fund under advisement. In so doing, Form PF requires the following information, primarily designed to evaluate systemic risk to the financial economy:
- AUM and use of leverage, including off-balance-sheet leverage;
- Counterparty credit risk exposure;
- Trading and investment positions;
- Valuation policies and practices of the fund;
- Types of assets held;
- Side arrangements or side letters, whereby certain investors in a fund obtain more favorable rights or entitlements than other investors;
- Trading practices; and
- Other information the SEC deems necessary to protect investors.
Proposed Changes
The proposed changes are a response to President Trump’s January 20, 2025 Presidential Memorandum, mandating the close review of pending rules issued by the previous administration.
The proposed amendments would eliminate filing requirements for smaller advisers, who represent almost half of the advisers currently required to file Form PF, by raising the filing threshold from $150 million in private fund AUM to $1 billion. The proposal would also raise the exposure reporting threshold for “large” hedge fund advisers from $1.5 billion in hedge fund AUM to $10 billion. Form PF would continue to obtain information on over 90 percent of private fund gross assets and require detailed exposure information for funds managed by large hedge fund managers.
Summary of Proposed Changes
Table 1a summarizes the proposed changes to the AUM-related filing threshold for all Form PF filers and the reporting threshold for large hedge fund advisers:
| Table 1a: Proposal to Increase Certain Thresholds | |
| Eliminate filing requirements for smaller advisers. | Increase the filing threshold for all filers from $150 million in private fund AUM to $1 billion. (Rule 204(b)-1(a) and General Instruction 1.) |
| Eliminate certain reporting requirements for smaller hedge fund advisers. | Increase the reporting threshold for large hedge fund advisers from $1.5 billion in hedge fund AUM to $10 billion. (General Instruction 3.) |
Table 1b summarizes the proposed changes to the reporting obligations:
| Table 1b: Proposed Changes to Reporting Obligations | |
| Eliminate separate reporting for certain feeder funds. | Currently, Form PF filers must separately report each component fund of masterfeeder arrangements and parallel fund structures, except under certain limited circumstances. The proposed amendments seek to eliminate this separate reporting requirement for any feeder fund that has de minimis holdings outside a single master fund, U.S. treasury bills, and/or cash and cash equivalents. (General Instruction 6.) |
| Eliminate “look through” requirements. | Currently, Form PF provides instructions for a filer to “look through” a reporting fund’s investments in other private funds and entities. The proposed amendments seek to eliminate the prescriptive “look through” requirements and allow filers to report indirect exposures based on reasonable estimates that are consistent with their internal methodologies and the conventions of service providers. (General Instructions 7 and 8, and conforming amendments to certain questions and asset classes in the Glossary of Terms.) |
| Eliminate identification requirements for certain trading vehicles. | Currently, if a reporting fund holds assets, incurs leverage, or conducts trading or other activities through a trading vehicle, the adviser must provide identifying information about each such trading vehicle. The proposed amendments seek to narrow the universe of trading vehicles that advisers must identify. (Question 9.) |
| Eliminate certain performance volatility reporting requirements. | Currently, if an adviser calculates a market value on a daily basis for any position in the reporting fund’s portfolio, it must report certain volatility information including aggregated calculated values, monthly annualized volatility of returns, and other data associated with the daily rates-of-return. The proposed amendments seek to eliminate these requirements. (Question 23(c).) |
| Eliminate certain trading and clearing reporting requirements. | Currently, filers must report how they use trading and clearing mechanisms, including the value traded over the reporting period and the value of positions at the end of the reporting period. The proposed amendments seek to eliminate the requirement to report the value of positions at the end of the reporting period. (Questions 29 and 30.) |
| Streamline adjusted exposure reporting. | Currently, large hedge fund advisers must report their qualifying hedge funds’ monthly adjusted exposures using multiple methods. The proposed amendments seek to eliminate one of the methods, so filers would no longer be required to report additional adjusted exposure based on the filer’s internal methodologies. (Question 32.) |
| Eliminate portfolio turnover reporting. | Currently, large hedge fund advisers must report the value of their qualifying hedge funds’ monthly turnover by asset class. The proposed amendments seek to eliminate this question. (Question 34.) |
| Reduce burdens associated with reporting North American Industry Classification System (“NAICS”) codes. | Currently, large hedge fund advisers must report their qualifying hedge funds’ monthly industry exposures when they exceed a certain amount, using the six-digit NAICS code that best describes the fund adviser’s primary business activity and principal source of revenue. The proposed amendments seek to provide flexibility to allow filers to report fewer digits of the NAICS codes for industry exposures. (Question 36; see the Glossary of Terms (defining “NAICS code.”) |
| Eliminate certain reporting concerning qualifying hedge funds’ monthly exposures to reference assets and, instead, include streamlined exposure reporting under an existing extraordinary loss current report trigger. | Currently, large hedge fund advisers must report details about their qualifying hedge funds’ monthly concentrated exposure to specific, position-level reference assets. The proposed amendments seek to eliminate those questions. Instead, if large hedge fund advisers file a current report about their qualifying hedge funds’ extraordinary investment losses, they would include a description of the largest exposure contributing to the loss. (Questions 39 and 40, and section 5, Item B.) |
| Simplify certain large hedge fund counterparty exposure reporting. | Currently, large hedge fund advisers must report in a consolidated counterparty exposure table their qualifying hedge funds’ borrowing, collateral received, lending, and posted collateral, all aggregated across all counterparties as of the end of each month. The proposed amendments seek to eliminate this table and direct large hedge fund advisers to: (1) complete the more simplified table in Question 26 for their qualifying hedge funds; and (2) report all borrowings to significant counterparties under Questions 42 and 43, and (3) categorize significant borrowing entries in Question 42. (Questions 41 and 42, and conforming amendments to Questions 18, 26, 43, and the Glossary of Terms.) |
| Eliminate rehypothecation reporting. | Currently, large hedge fund advisers must report the total amount of collateral posted by counterparties to the qualifying hedge fund that may be and has been rehypothecated by the qualifying hedge fund. The proposed amendments seek to eliminate these questions. (Question 45.) |
| Modify the current reporting trigger for all current reports. | Currently, section 5 requires large hedge fund advisers to file a current report “as soon as practicable, but no later than 72 hours” upon the occurrence of certain events at their qualifying hedge fund. The SEC proposes to modify the reporting trigger by removing the requirement to report as soon as practicable. Under the proposal, large hedge fund advisers would have the full 72 hours to file a current report. (Section 5.) |
| Eliminate current reporting for large hedge fund advisers concerning certain margin defaults. | Currently, large hedge fund advisers are required to report within 72 hours if their qualifying hedge fund is in margin default or is unable to meet a call for margin, collateral, or equivalents. The SEC proposes to eliminate this requirement. (Section 5, Item D.) |
| Eliminate current reporting for certain operations events. | Currently, large hedge fund advisers are required to report within 72 hours if their qualifying hedge fund client experiences an operations event (i.e., a significant disruption or degradation of the fund’s “critical operations”). Form PF defines “critical operations” as operations necessary for (1) the investment, trading, valuation, reporting, and risk management of the reporting fund; or (2) the operation of the reporting fund in accordance with the Federal securities laws and regulations. The SEC proposes to eliminate the second element. (Section 5, Item G, and the Glossary of Terms.) |
| Eliminate current reporting related to the inability to satisfy redemption requests. | Currently, large hedge fund advisers are required to report within 72 hours if their qualifying hedge fund (1) is unable to pay redemption requests or (2) has suspended redemptions and the suspension lasts for more than five consecutive business days. The SEC proposes to eliminate the first element. (Section 5, Item I.) |
| Eliminate quarterly event reporting for all private equity fund advisers. | Currently, all private equity fund advisers must submit quarterly reports about adviser-led secondary transactions, general partner removals, termination of investment periods, and fund terminations. The SEC proposes to eliminate this requirement. (Section 6.) |
| Corrections and other revisions. | The proposed amendments seek to make corrections and other revisions to help ensure filers clearly understand Form PF requirements. |
| Request for comments on private credit reporting. | The proposal requests comments on all the proposed amendments. |
Whistleblowers play a critical role in ensuring the integrity of the U.S. and global financial markets. Both the SEC and CFTC rely on whistleblowers to help them enforce violations of the federal securities laws and the Commodity Exchange Act, respectively. If you have witnessed fraud, consider blowing the whistle.
What to Do if You Have Witnessed Fraud:
- Speak with an Experienced Whistleblower Attorney: Contact an experienced whistleblower attorney who understands the SEC and CFTC whistleblower programs. These consultations at Cohen Milstein are confidential and free of charge. Counsel can guide you through the process and assist in preparing and submitting your Tip, Complaint, and Referral (Form TCR) to the SEC or CFTC.
- Gather Your Information: Along with your personal observations and a completed Form TCR, the SEC and CFTC requires supporting information that is original and not in the public sphere.
- Understand the Potential for a Whistleblower Award: If your information leads to a successful SEC or CFTC enforcement action resulting in more than $1 million in monetary sanctions, you may receive an award ranging from 10-30% of any amount collected.
The SEC’s Whistleblower Program and the CFTC’s Whistleblower Program provide comprehensive guidelines on reporting fraud and the whistleblower process. Access the Tip, Complaint or Referral (TCR) forms: SEC Form TCR and the CFTC Form TCR.
About the Author
Christina McGlosson, special counsel in Cohen Milstein’s Whistleblower practice, focuses exclusively on Dodd-Frank Whistleblower representation. She is the former acting director of the Whistleblower Office in the Division of Enforcement at the U.S. Commodity Futures Trading Commission. She was a senior attorney in the SEC’s Division of Enforcement, where she assisted in drafting the SEC rules to implement the whistleblower provisions of Dodd-Frank and served as Senior Counsel to the Director of the SEC’s Division of Enforcement and to the SEC’s Chief Economist.
Christina represents whistleblowers in the presentation and prosecution of fraud claims before the SEC, CFTC, FinCEN, as part of the U.S. Treasury, the Department of Justice, and other government agencies.