SEC and CFTC Propose Landmark Rollback of Private Fund Reporting Requirements to Ease Compliance Burdens

WASHINGTON, D.C. — April 20, 2026 — In a significant pivot toward regulatory relief for the investment management industry, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have jointly unveiled a sweeping proposal to amend Form PF. The initiative aims to recalibrate the reporting landscape for private fund advisers, slashing the compliance burden for smaller firms while streamlining data collection for the nation’s largest hedge fund managers.

The proposal, announced Monday, represents a strategic effort by federal regulators to refine the post-financial-crisis disclosure framework. By raising filing thresholds and eliminating redundant reporting, the agencies seek to allow investment advisers to refocus their resources on core fiduciary duties and investment strategy, rather than navigating the increasingly labyrinthine requirements of federal oversight.

The Core Facts: A New Regulatory Framework

Form PF—the confidential reporting tool established in the wake of the 2008 financial crisis—has long served as a primary instrument for the Financial Stability Oversight Council (FSOC) to track systemic risk. However, critics within the industry have long argued that the form evolved into an "over-collection" machine, forcing smaller firms to dedicate massive amounts of capital and personnel to filing data that regulators rarely utilized.

Under the newly proposed amendments, the regulatory landscape for private fund advisers will undergo two primary structural changes:

1. Increased Filing Thresholds: The SEC and CFTC are proposing to raise the threshold for mandatory Form PF filing from $150 million in private fund assets under management (AUM) to $1 billion. This change alone would exempt nearly 50% of the currently registered advisers from filing requirements.
2. Adjusted Hedge Fund Reporting: For "large" hedge fund advisers, the threshold for exposure reporting will be raised from $1.5 billion to $10 billion in hedge fund AUM.

Despite these higher thresholds, the regulators maintain that the data collection remains robust. According to agency estimates, the amended Form PF will still capture data representing over 90% of the private fund industry’s gross assets, ensuring that the FSOC retains sufficient visibility into systemic risks while removing the "noise" generated by smaller market participants.

Chronology of Regulatory Evolution

The evolution of Form PF reflects the changing attitudes toward oversight in Washington.

• 2011: Following the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the SEC and CFTC jointly adopted Form PF. It was designed to provide the FSOC with information to assess systemic risk.
• 2015–2022: Throughout this period, successive amendments steadily expanded the scope of Form PF, adding more granular data requirements, particularly following market volatility events.
• 2023–2025: The industry experienced what many dubbed "reporting fatigue," as the cumulative cost of compliance—comprising legal fees, data aggregation software, and internal staffing—reached record highs, disproportionately impacting mid-sized and smaller advisory firms.
• April 2026: The current proposal marks the first significant contraction of these requirements, signaling a shift in policy toward efficiency and economic relief for the financial sector.

Supporting Data: Efficiency Through Threshold Adjustments

The rationale for these amendments is rooted in a cost-benefit analysis conducted by the SEC’s Division of Investment Management. The data suggests that while the reporting burden has grown exponentially, the utility of the data provided by smaller firms has remained marginal for systemic risk monitoring.

The Private Credit Monitoring Initiative

A notable addition to the proposal is the inclusion of a specialized mechanism to identify funds active in the private credit market. As private credit has exploded in popularity—moving from a niche corner of finance to a dominant source of corporate lending—regulators have recognized that existing forms were ill-equipped to capture this transition. By streamlining the form for smaller firms, the agencies are simultaneously sharpening their focus on this emerging systemic risk, allowing for more precise data collection where it matters most.

The Burden of Scale

The SEC’s internal review found that for many advisers managing between $150 million and $1 billion, the cost of filing Form PF could account for a significant percentage of their operational budget. By shifting the burden, the agency expects to see an immediate reduction in the "administrative drag" that has hampered smaller advisory shops. For these firms, the removal of the filing requirement is not just a reduction in paperwork; it is a redirection of capital that can be used to improve investment performance or reduce fees for underlying investors.

Official Responses: Aligning Disclosure with Purpose

The proposal received strong backing from the leadership of both agencies, emphasizing a desire to return to the original intent of the Dodd-Frank mandates.

SEC Perspective: Restoring Balance

SEC Chairman Paul S. Atkins, a vocal proponent of reducing regulatory friction, framed the proposal as a necessary correction. "A key pillar of my agenda is restoring balance to disclosure obligations and reducing the cost of compliance wherever possible," Atkins stated during the public unveiling.

He further noted that the previous iterations of Form PF had drifted into a "compliance-first" model that distracted advisers from their core investment functions. "These proposed changes would help to rationalize the scope of Form PF requirements to support its purpose and bring our overall disclosure regime back into alignment," Atkins added.

CFTC Perspective: Efficiency and Transparency

CFTC Chairman Michael S. Selig echoed these sentiments, highlighting the agency’s commitment to evidence-based regulation. "By raising the filing threshold and streamlining Form PF, we are taking steps to reduce the burdens associated with filing the form," Selig noted. He emphasized that the agency is now in a "listening phase," inviting public comment to ensure that the final rules effectively eliminate unnecessary costs without compromising the integrity of the data stream.

Implications for the Financial Markets

The implications of this proposal are far-reaching, touching on everything from operational costs to the competitive landscape of the hedge fund industry.

1. Operational Relief for Boutique Firms

For mid-sized advisers, the proposed $1 billion threshold is a major win. Many of these firms operate with lean teams where compliance duties often fall on senior investment personnel. Relieving them of Form PF obligations will likely lead to increased agility and a potential reduction in fees for clients.

2. Sharpening the Focus on Systemic Risk

By pruning the number of filers, regulators are theoretically increasing the quality of the data they receive. Instead of processing thousands of filings from smaller firms that have little impact on the macro-financial environment, the SEC and CFTC can focus their analytical resources on the $10 billion-plus "mega-funds" whose activities are the most likely to have ripple effects across the global economy.

3. The Future of Private Credit Oversight

The introduction of a specific "private credit tag" on the new form suggests that while the regulators are rolling back broad reporting, they are increasing their scrutiny of specific, high-growth sectors. This signals a trend toward "targeted oversight"—a shift away from universal reporting toward risk-based reporting.

4. Market Reaction and Public Comment

The financial industry is expected to respond positively to the proposal, though some investor advocacy groups may express concern regarding the reduction in transparency for funds between $150 million and $1 billion. The 60-day public comment period will be critical. The SEC and CFTC have made it clear that they are open to refining the proposal, particularly regarding how they define "private credit" and the transition periods for firms moving above the $1 billion AUM threshold.

Conclusion: A New Era of Regulatory Pragmatism

The joint proposal to amend Form PF marks a pivotal moment in the 2026 regulatory calendar. By moving toward a more streamlined, targeted, and cost-effective disclosure regime, the SEC and CFTC are acknowledging that the burden of regulation must be commensurate with the systemic risk managed by the firm.

As the proposal moves toward the Federal Register, the focus shifts to the industry’s response. Will the 60-day comment period lead to further refinements, or will the current proposal serve as the blueprint for the next phase of the private fund regulatory regime? One thing is certain: for the thousands of investment advisers currently grappling with the weight of Form PF, the promise of a simplified future is a welcome development in an increasingly complex financial landscape.

Regulators have invited all interested parties—from large hedge fund managers to small-scale private equity advisers—to weigh in on the specifics of the amendments, ensuring that the final rule is as durable and efficient as the markets it intends to monitor.