The SEC and CFTC jointly issued a proposal to significantly amend and reduce Form PF reporting requirements for certain registered investment advisers to private funds. If adopted, the proposal would eliminate Form PF filing requirements for small and mid-sized private fund managers and would only be applicable to private fund managers with more than $1 billion in private fund assets under management (AUM), and the large hedge fund definition would be increased to $10 billion in hedge fund assets AUM. This would reduce the number of large HF managers subject to quarterly reporting on Section 2 of Form PF and current reporting on Section 5 within 72 hours of certain events related to investment losses, market volatility, and liquidity. Moreover, the events triggering Section 5 reporting would be scaled back. Private equity firms would no longer be subject to reporting on Section 6 in the event of material governance changes, early termination, and adviser-led secondaries. Other proposed changes would reduce Form PF reporting burden resulting from prior amendments to Form PF applicable to large hedge funds or all filers.

The proposal will be open for comment for at least 60 days and will not impact Form PF reporting that is due by April 30, large hedge fund reporting that is due by May 29, or any required material event disclosures under Section 5 or 6 in the near term. The SEC has proposed at least a 12-month transition period prior to a compliance date after adoption, but has requested comment on the proposed transition period. The SEC noted that they are mindful of the October 1, 2026 compliance date for the 2024 amendments and will consider how the timing of amendments that are adopted relate to that timing. We will continue to monitor the status of this proposal and its impact on future Form PF reporting obligations of clients.