For more than a decade, Form PF has been one of the more demanding items on the private fund compliance calendar. That may be about to change. On April 20, 2026, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly proposed a set of amendments that would pull back a meaningful portion of what advisers report today and, in many cases, remove the filing obligation altogether.
The proposal reflects a shift in the agencies’ approach. SEC Chairman Paul Atkins framed the proposal around “restoring balance to disclosure obligations and reducing the cost of compliance wherever possible.” He said prior expansions of the form had created “overly burdensome disclosure requirements” that pulled advisers away from their core work without a matching benefit to regulators. For firms that have spent the past two years preparing for a heavier version of Form PF, that is a notable change in direction.
The proposal could provide meaningful relief, but it is not final, and firms that treat it as final could be caught off guard. The value here is not only the burden the proposal removes. It is the signal it sends about where private fund reporting is headed.
Here is what the proposal would actually do.
The headline change is the filing threshold. Today, an adviser generally has to file Form PF once it reaches $150 million in private fund assets under management. The proposal would raise that floor to $1 billion. By the agencies’ own estimate, that one change would lift the requirement off nearly half of the advisers who file today, while Form PF would still capture information on more than 90 percent of private fund gross assets.
The definition of a “large hedge fund adviser” would also move from $1.5 billion in hedge fund assets under management to $10 billion. Advisers who fall below the new line would no longer carry the more detailed exposure reporting that comes with that label. The proposal also asks SEC staff to revisit these thresholds roughly every five years, an indication the agencies likely want the form to track the industry over time rather than sit frozen in place.
Raising the thresholds is only part of the story. The proposal would also trim or eliminate a long list of specific requirements for advisers who still have to file. Private equity fund advisers, for example, would no longer file the quarterly event reports introduced by the 2024 amendments. The agencies reviewed more than two years of those filings and concluded they mostly reflected firm-specific events rather than early signals of anything systemic.
Other items expected to fall away include separate feeder fund reporting, look-through requirements for certain structures, portfolio turnover reporting, rehypothecation reporting, and several trading and clearing questions. The proposal also revisits how large hedge fund advisers report counterparty and reference-asset exposure, to simplify both.
The limits matter too. The threshold for large private equity fund advisers stays at $2 billion. The broad definition of “hedge fund” was left untouched, so some funds that may not commonly be viewed as hedge funds could still fall within the definition. And large private equity advisers would keep collecting portfolio company borrowing information. The proposal could provide meaningful relief, but it would not create a clean slate.
Two groups stand to gain the most. The first is the mid-sized manager sitting between $150 million and $1 billion, who could move from filer to non-filer and retire a compliance process built specifically for this form. The second is the hedge fund adviser between $1.5 billion and $10 billion, who would drop out of the heavier large-adviser reporting and file under the lighter framework instead. For both, this is not a trim around the edges. It is a potential exit from certain reporting requirements that advisers may want to evaluate while continuing to comply with the current rule.
There is a bigger message underneath the line items. The agencies are moving from a “collect everything that might be useful” posture to a “collect what we actually use” one. The proposed five-year review of the thresholds aligns with that idea, since it is meant to keep the form calibrated over time rather than frozen. If that approach continues, Form PF reporting could become more stable and proportionate after several years of expansion.
Private credit is the exception to the lighter touch, and it deserves a closer look. While the agencies are paring back legacy hedge fund reporting, they used this proposal to ask how they should track private credit activity. For managers in that space, the proposal is not solely about reducing reporting obligations. It also offers insight into how regulators are currently thinking about private credit reporting.
There is an important timing point that is easy to overlook. Because the proposal reduces burdens, it is natural to assume some of the pressure is off. For now, it is not. The 2024 amendments that this proposal would soften still carry a compliance date of Oct. 1, 2026, and that date has not moved. The proposal is still only a proposal. The comment period closed on June 23, 2026, and as of the date of this article, the agencies have not issued a final rule adopting the proposed amendments. With the Oct. 1, 2026, compliance date approaching, advisers may want to continue preparing rather than assume relief will arrive before that date. The Commissions have said they will address how the pending 2024 amendments interact with any final rule, unless and until a final rule changes the requirements, Oct. 1 remains the applicable compliance date.
The comment window has closed, so the next move belongs to the agencies. That is not a reason to stand still. Advisers may want to assess where they fall against the proposed $1 billion and $10 billion thresholds and identify which current Form PF obligations would change if the proposal is adopted as written. Keep in mind that dropping below the Form PF threshold would not eliminate all reporting obligations, since those advisers would still report fund information on Form ADV and stay subject to the usual recordkeeping rules. For now, advisers may want to continue preparing for the rule currently in effect while positioning their programs to adjust efficiently if a final rule is adopted.
Withum’s Financial Services and Private Equity Services Teams help fund managers turn moving targets into a clear plan. Reach out to discuss how the proposed amendments could affect Form PF obligations and related compliance processes.
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