The 2nd quarter of 2026 included several noteworthy developments for private fund managers and other investment advisers. In April, the SEC and CFTC jointly proposed amendments to Form PF that would materially increase the filing threshold from $150 million to $1 billion and reduce or eliminate the filing burden for many smaller private fund managers. The Form PF proposal specifically requested public comment on identifying and reporting private credit funds and whether private-credit-specific reporting should eventually be adopted. Regulators expressly highlighted private credit as an area requiring additional visibility and future policy consideration.
April 21 marked the one-year anniversary of the swearing in of SEC Chairman Paul Atkins, who has clearly set the tone for the agency’s focus as described in his speech on the anniversary date. While SEC enforcement activity during his tenure reflects lower volume than historical peaks, it nonetheless reflects renewed emphasis on high‑impact, fraud‑centric cases targeting investor harm and fiduciary breaches. Significantly, in May, the SEC rescinded its longstanding policy requiring settling defendants in enforcement actions to refrain from publicly denying SEC allegations, materially changing the enforcement landscape for advisers facing SEC investigations.
At the Milken Institute Global Conference on May 4, 2026, Atkins outlined a regulatory agenda centered on market growth and innovation, disclosure modernization, and regulatory efficiency, while reaffirming the SEC's core mission of investor protection, capital formation, and fair, orderly markets. Consistent with this message, the SEC's June 2026 draft Strategic Plan signaled a broader shift toward supporting investment and market development, promoting market efficiency, facilitating compliance, and modernizing the agency's regulatory framework while maintaining appropriate investor safeguards. The SEC is likely to prioritize modernization and simplification of disclosure requirements, retrospective review of existing regulations, greater stakeholder engagement in the rulemaking process, and regulatory approaches designed to reduce unnecessary burdens on market participants while preserving market integrity and investor confidence.
The SEC, CFTC, and NFA continued collaboration efforts. In June, the SEC and CFTC jointly sought public comment regarding: 1) harmonization of derivatives product definitions; 2) swap and security-based swap reporting frameworks; and 3) portfolio margining frameworks, signaling potential future changes in reporting and regulatory requirements for hedge funds, credit funds, and other derivatives managers.
Standish Compliance's Q2 2026 Regulatory Update summarizes noteworthy enforcement activity, rulemaking and guidance.
