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ARTICLE · 28 APRIL 2026

SEC And CFTC Propose Sweeping Amendments To Form PF

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The SEC and CFTC have jointly proposed sweeping amendments to Form PF that would dramatically reduce compliance burdens for private fund advisers by raising filing thresholds from $150 million...

United StatesFinance and Banking
Leslie S. Cruz
Leslie S. Cruz
Jodi Erlandsen
Jodi Erlandsen
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Robert Kim
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On April 20, 2026, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) (collectively, the “Commissions”) jointly proposed sweeping amendments to Form PF (the “Proposed 2026 Amendments,” and the announcement the “Proposing Release”). If adopted as proposed, the amendments would significantly reduce—and in many cases, eliminate—Form PF compliance obligations for a considerable portion of the filing population.1 The Proposed 2026 Amendments follow the Commissions’ February 2024 adoption of significant amendments to Form PF (the “2024 Amendments”),2 and subsequent multiple extensions of the compliance date for those amendments, including the most recent extension to October 1, 2026.3 At the time of that most recent extension, the Commissions stated that they further extended the compliance date of the 2024 Amendments to (1) address certain challenges associated with the reporting cycle timing; (2) provide the industry more time to comply

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