SEC And CFTC Propose New Form PF Amendments

Key Takeaways

• On April 20^th, the SEC and the CFTC (the “Commissions”) released a joint proposal (the “Proposal”) to amend Form PF.
• This Proposal would entirely eliminate reporting obligations for advisers with less than US$1 billion in private fund AUM and raise the reporting threshold for large hedge fund advisers from US$1.5 billion to US$10 billion in hedge fund AUM.
• The Proposal solicits input from advisers on the treatment of private credit funds, streamlines certain requirements, and corrects errors and inconsistencies throughout the form.
• The Proposal also curtails the “current” reporting requirements the SEC implemented for large hedge fund advisers two years ago.
• Although the Proposal would reduce reporting burdens for some advisers, it does little to reduce the overall scope of the form.