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Alternative Market Briefing

SEC and CFTC propose major rollback of Form PF reporting requirements

Tuesday, April 21, 2026

Matthias Knab, Opalesque for New Managers:

The Securities and Exchange Commission and Commodity Futures Trading Commission have jointly proposed sweeping amendments to Form PF that would significantly reduce the reporting burden on private fund advisers, marking a sharp reversal from the expansive 2024 requirements that had drawn widespread criticism from industry participants.

The proposal, published as Release No. IA-6959, would raise the general filing threshold from $150 million in private fund assets under management to $1 billion - a more than six-fold increase. According to the agencies' own estimates, this single change would eliminate filing obligations for almost half of all advisers currently required to file Form PF. At the same time, the Commissions project that the revised threshold would still capture over 90 percent of private fund gross asset value currently reported, preserving the systemic risk oversight function that underpins the form's statutory justification.

For large hedge fund advisers, the proposed changes are equally significant. The reporting threshold would rise from $1.5 billion in hedge fund assets under management to $10 billion - a more than six-fold increase - which the agencies estimate would eliminate certain reporting obligations for approximately two-thirds of advisers currently classified as large hedge fund advisers. The C......................

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