SEC and CFTC Jointly Propose Amendments to Reduce Private Fund Reporting Burdens

On April 20, 2026, the U.S. Securities and Exchange Commission (“SEC”)  and the Commodity Futures Trading Commission (“CFTC”) jointly proposed to amend Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, including those that also are registered with the CFTC as commodity pool operators or commodity trading advisors. You can read the press release here: SEC.gov | SEC and CFTC Jointly Propose Amendments to Reduce Private Fund Reporting Burdens, and the proposed new amendments ia-6959.pdf. 

The purpose of many of the amendments is to lower the burden on private fund managers. The agencies feel as if recent amendments have increased cost of compliance, while data being collected is often without a corresponding benefit. 

The proposed amendment would: 

• Eliminate Form PF filing requirements for smaller advisers (filing threshold would be increased from $150 million in private fund assets under management to $1 billion); 

• “Large” hedge fund advisers definition would be raised from $1.5 billion in hedge fund assets under management to $10 billion; and 

• The proposal will also pare back some of the 2024 amendments and other information currently required by Form PF, see list of changes below: 

• • Eliminate separate reporting for certain feeder funds;  

• • Eliminate “look through” requirements;  

• • Eliminate identification requirements for certain trading vehicles.  

• • Eliminate certain performance volatility reporting requirements;  

• • Eliminate certain trading and clearing reporting requirements;  

• • Streamline adjusted exposure reporting;  

• • Eliminate portfolio turnover reporting;  

• • Reduce burdens associated with reporting North American Industry Classification System (“NAICS”) codes;  

• • 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;  

• • Simplify certain large hedge fund counterparty exposure reporting; 

• • Eliminate rehypothecation reporting;  

• • Modify the current reporting trigger for all current reports;  

• • Eliminate current reporting for large hedge fund advisers concerning certain margin defaults;  

• • Eliminate current reporting for certain operations events; 

• • Eliminate current reporting related to the inability to satisfy redemption requests; and 

• • Eliminate quarterly event reporting for all private equity fund advisers. 

Please reach out to a member of our team if you have any questions, would like to discuss what this means for your reporting obligations, or for assistance with preparing a comment letter. Comments are due 60 days after publication in the Federal Register.  

This summary is provided for informational purposes only and is not intended to constitute legal advice nor does it create an attorney-client relationship with Rimon, P.C. or its affiliates.