SEC and CFTC Ease Up on Investment Adviser Paperwork Burdens
Published Date: 4/24/2026
Proposed Rule
Summary
If you’re an investment adviser filing Form PF, big news! The SEC and CFTC want to make your life easier by cutting some reporting chores, fixing confusing rules, and streamlining the whole process. You’ve got until June 23, 2026, to share your thoughts before these changes could save you time and hassle.
Free Policy Watch
New rules are filed every week. Most people never see them.
Pick a topic. PRIA watches every federal rule and tells you when one hits your household.
Pick a topic to get started
Analyzed Economic Effects
19 provisions identified: 18 benefits, 0 costs, 1 mixed.
Raise Form PF Filing Threshold
The Commissions propose raising the Form PF filing threshold for all filers from $150 million to $1 billion in private fund assets under management. The proposal would remove filing obligations for almost half of advisers who currently must file, while the agencies estimate Form PF would still cover about 94 percent of private fund gross asset value reported.
Raise Large Hedge Fund Reporting Threshold
The Commissions propose increasing the large hedge fund adviser reporting threshold from $1.5 billion to $10 billion in hedge fund assets under management. The change would remove large-hedge-fund filing and quarterly reporting duties for about two-thirds of advisers that currently qualify as large hedge fund advisers, while still capturing quarterly data on over 80 percent of hedge fund gross asset value reported.
End Separate Feeder-Fund Reporting
The proposal would eliminate separate Form PF reporting for feeder funds that have only de minimis holdings outside a single master fund, U.S. Treasury bills, and/or cash and cash equivalents. Advisers would no longer need to report each feeder fund separately in those cases.
Remove Prescriptive 'Look-Through' Rules
The Commissions propose eliminating the prescriptive Form PF 'look through' requirements. Filers would be allowed to report indirect exposures based on reasonable estimates consistent with their internal methodologies and service-provider conventions, instead of following prescriptive look-through instructions.
Drop Internal-Methodology Adjusted Exposures
For large hedge fund advisers, the Commissions propose eliminating the requirement to report additional monthly adjusted exposures based on the adviser's internal methodologies (Question 32(b)(2)). Advisers would continue to report adjusted exposures using other methods but not the internal-methodology approach.
Simplify Counterparty Exposure Tables
The Commissions propose eliminating the consolidated counterparty exposure table for large hedge fund advisers and directing advisers to use a simpler table in Question 26, report borrowings to significant counterparties under Questions 42 and 43, and categorize significant borrowing entries in Question 42.
Remove Current Reporting for Margin Defaults
The SEC proposes to eliminate the requirement that large hedge fund advisers file a current report within 72 hours for notice of margin default or a determination of inability to meet a call for margin, collateral, or equivalents (Section 5, Item D).
Remove Current Reporting for Inability To Pay Redemptions
The SEC proposes to eliminate the current-report trigger that required large hedge fund advisers to report within 72 hours if a qualifying hedge fund is 'unable to pay redemption requests' (Section 5, Item I), while retaining reporting for suspension of redemptions lasting more than five consecutive business days.
End Private Equity Quarterly Event Reporting
The proposal would eliminate Form PF Section 6 quarterly event reporting for private equity fund advisers, removing the requirement to submit quarterly reports about adviser-led secondary transactions, general partner removals, investment-period terminations, and fund terminations.
Narrow Trading-Vehicle Identification
The proposal would narrow the set of trading vehicles that advisers must identify on Form PF (Question 9), reducing the identification and reporting obligations for advisers that conduct trading through certain vehicles.
Eliminate Volatility Performance Reporting
The Commissions propose to eliminate daily-based performance volatility reporting requirements in Form PF Question 23(c), removing the need to report aggregated calculated daily values and monthly annualized volatility of returns when advisers calculate daily market values.
Remove End-of-Period Position Values
The proposal would eliminate the current Form PF requirement to report the value of positions at the end of the reporting period for trading and clearing (Questions 29 and 30). Advisers would no longer need to submit end-of-period position values in those items.
Eliminate Monthly Asset Turnover Question
The proposal would remove the Form PF Question 34 requirement that large hedge fund advisers report monthly asset turnover by asset class.
Simplify NAICS Industry Exposure Reporting
The Commissions propose allowing filers to report fewer digits of NAICS codes for industry exposure reporting (Question 36) instead of requiring the full six-digit NAICS codes, reducing the granularity required for monthly industry exposure reports.
Remove Certain Reference-Asset Exposure Questions
The proposal would eliminate certain monthly questions about qualifying hedge funds' exposures to reference assets (Questions 39 and 40). Instead, advisers filing an extraordinary loss current report would include a description of the largest exposure contributing to the loss.
Eliminate Rehypothecation Reporting
The proposal would eliminate Form PF questions that require large hedge fund advisers to report amounts of collateral posted by counterparties that may be or have been rehypothecated by the qualifying hedge fund (Question 45).
Relax Current-Report Timing to Full 72 Hours
The SEC proposes to modify the Form PF current-report trigger so large hedge fund advisers would have the full 72 hours to file a current report, removing the prior 'as soon as practicable, but no later than 72 hours' language.
Narrow Operations-Event Reporting
The SEC proposes to eliminate the requirement to report within 72 hours when a qualifying hedge fund experiences an operations event defined as 'the operation of the reporting fund in accordance with the Federal securities laws and regulations' (Section 5, Item G), keeping reporting only for disruption to investment, trading, valuation, reporting, and risk management functions.
Request for Comment on Private Credit Reporting
The Commissions are requesting public comment on whether to modify the information advisers must report about private credit funds; stakeholders may submit feedback by the June 23, 2026 comment deadline.
Your PRIA Score
Personalized for You
How does this regulation affect your finances?
Sign up for a PRIA Policy Scan to see your personalized alignment score for this federal register document and every other regulation we track. We analyze your financial profile against policy provisions to show you exactly what matters to your wallet.
Key Dates
Department and Agencies
Take It Personal
Get Your Personalized Policy View
Take the PRIA Score to see how policy affects your household, then upgrade to PRIA Full Coverage for year-round monitoring.
Already have an account? Sign in