Client Alert: Form PF: SEC and CFTC Propose Raising the Filing Threshold to $1 Billion

May 7, 2026

On April 20, 2026, the SEC and CFTC issued a joint proposal that would materially narrow the universe of advisers required to file Form PF by raising the minimum private fund AUM threshold from $150 million to $1 billion. Form PF is a confidential regulatory reporting form used by certain SEC-registered investment advisers (including those that are also registered with the CFTC as a commodity pool operator or commodity trading advisor) to report information about the private funds they advise.

The proposal aims to recalibrate the scope of Form PF (and related burdens). Today, an SEC-registered investment adviser generally must file Form PF if it advises one or more private funds and it and its related persons, collectively, have at least $150 million in private fund assets under management. The proposal would increase that minimum filing threshold to $1 billion, meaning many advisers that currently file Form PF would no longer be Form PF filers (though those advisers below the reporting threshold would continue to file Form ADV and otherwise remain subject to applicable Advisers Act recordkeeping and compliance obligations).

Both the SEC and CFTC (the “Agencies”) have noted that the goal is to reduce reporting obligations for smaller advisers, while retaining coverage over a significant share of private fund assets. In the release’s economic analysis, the Agencies indicate that raising the threshold to $1 billion would significantly reduce the percentage of SEC-registered private fund advisers required to file Form PF (from roughly 70% today to around 40%), while still capturing approximately 94% of private fund gross assets reported by SEC-registered advisers.

This proposal also comes against the backdrop of the SEC’s multi-year effort to modernize Form PF, including amendments adopted as recently as 2024 (the compliance date for which has been extended to October 1, 2026), as well as a broader review of Form PF in light of subsequent developments and market feedback. Comments on the proposal are due within 60 days of publication on the Federal Register.

Who May Be Most Affected?

If adopted as proposed, the threshold change could be particularly relevant for:

  • Private fund advisers with between $150 million and $1 billion in private fund AUM that currently incur the cost and operational burden of Form PF reporting, including data mapping, service-provider coordination, and internal controls around periodic submissions.
  • Managers near the proposed $1 billion line, who may need to evaluate how they monitor and calculate private fund AUM for reporting purposes (including potential volatility around measurement dates and the impact of aggregation with any “related persons”).
  • Private equity fund advisers that have been preparing for or implementing quarterly event reporting, as the proposal would eliminate that quarterly reporting layer entirely.

Other Notable Elements of the Proposal

In addition to the threshold increase, the proposal includes other changes that would, among other things, modify who is treated as a “large hedge fund adviser” by increasing the reporting threshold from $1.5 billion to $10 billion in hedge fund AUM.

The proposal and corresponding SEC fact sheet also highlight a series of proposed “clean-up” and burden-reducing changes that adjust and/or eliminate a number of the current questions. While the full impact will vary by sponsor strategy and structure, key proposals include (but are not limited to):

  • narrowing certain “look through” requirements;
  • eliminating certain performance volatility reporting;
  • eliminating certain trading, clearing and exposure questions;
  • simplifying certain industry concentration, collateral and large hedge fund counterparty exposure reporting; and
  • perhaps most significantly, eliminating quarterly event reporting for private equity fund advisers.

Practical Considerations

For advisers that currently file Form PF and would fall below the proposed $1 billion AUM threshold, the proposal, if adopted, could translate into meaningful reporting relief.

In the interim, advisers should: (i) confirm their current private fund AUM calculations and filing status, including the aggregation of related persons; (ii) assess how the proposal would affect their particular fund mix (e.g., hedge funds, private equity funds, and private credit vehicles) and their “large adviser” status under Form PF; and (iii) evaluate operational processes built around Form PF data production.

If the proposal is not adopted before the compliance date of October 1, 2026 for the previously issued Form PF amendments, advisers should assume the existing compliance timeline and reporting obligations remain in place and plan accordingly. Potentially affected advisers may view the 60-day comment window as an opportunity to provide strategy-specific, quantitative feedback to the Agencies.

This summary is provided for general informational purposes and does not constitute legal advice. If you have any further questions, please contact your CFDB attorney, Jacob Kupferman (jkupferman@crokefairchild.com) or Jennifer Kalmanides (jkalmanides@crokefairchild.com).