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ARTICLE · 22 APRIL 2026

Form PFffft: SEC And CFTC Propose Rolling Back Reporting Burdens For Private Fund Managers

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On 20 April 2026, the SEC and CFTC jointly proposed yet another round of amendments to Form PF to eliminate filing obligations for many private fund advisers...

United StatesFinance and Banking
Thoreau Bartmann
Thoreau Bartmann
Richard Burnett
Richard Burnett
Ruth E. Delaney
Ruth E. Delaney
Lance Dial
Lance Dial
Pablo Man
Pablo Man
Sarah V. Riddell
Sarah V. Riddell

On 20 April 2026, the SEC and CFTC jointly proposed yet another round of amendments to Form PF to eliminate filing obligations for many private fund advisers and reduce burdens for many of those who remain subject to the form.

Form PF was originally adopted as a means to monitor systemic risk in the financial markets. However, over time the form's requirements expanded significantly, particularly in 2023 and 2024, prompting significant pushback from industry participants who raised concerns about the technological and administrative burdens of compliance. This proposal reflects a fresh look at the Form, taking it "back to basics." The key changes include:

  • Higher Reporting Thresholds: The proposal would raise the filing threshold from US$150 million to US$1 billion in private fund assets under management. The large hedge fund adviser reporting threshold would also rise from US$1.5 billion to US$10 billion in hedge fund assets under management. These changes would reduce by almost

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