SEC and CFTC Propose Easier Reporting for Investment Advisers
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. These changes kick in after June 23, 2026, so get ready to save time and maybe some money too!
Analyzed Economic Effects
12 provisions identified: 11 benefits, 0 costs, 1 mixed.
Raise Form PF Filing Threshold to $1B
If you’re an SEC-registered investment adviser to private funds, the Commissions propose raising the Form PF filing threshold from $150 million to $1 billion in private fund assets under management. The proposal estimates almost half of current filers would no longer need to file Form PF while Form PF would still cover about 94 percent of private fund gross asset value reported.
Big Hedge Funds Only: $10B Reporting Cutoff
Large hedge fund reporting would require advisers to have $10 billion in hedge fund assets under management instead of $1.5 billion. The proposal estimates almost two-thirds fewer advisers would be subject to large-hedge-fund reporting while still capturing over 80 percent of hedge fund gross asset value reported.
Narrow and Slow Some Current Reporting Triggers
For large hedge fund advisers, the SEC proposes changing the current-reporting rule so advisers would have the full 72 hours to file (removing 'as soon as practicable') and eliminating certain current reporting triggers, including (1) notice of margin default or inability to meet a margin call, (2) one element of operations-event reporting (the element about operation of the fund in accordance with Federal securities laws), and (3) reporting when a fund is 'unable to pay' redemption requests (while retaining other redemption-related reporting). These changes are in Section 5.
End Separate Feeder-Fund Reporting
Advisers would no longer need to separately report each component feeder fund of master-feeder or parallel fund structures if a feeder has only de minimis holdings outside a single master fund, U.S. Treasury bills, and/or cash and cash equivalents. This change is proposed in General Instruction 6.
Remove Prescriptive 'Look-Through' Rules
Form PF would remove the prescriptive 'look-through' instructions and allow filers to report indirect exposures using reasonable estimates consistent with their internal methodologies and service provider conventions. This change appears in General Instructions 7 and 8 and related conforming amendments.
Remove End-of-Period Positions Reporting
Form PF would no longer require advisers to report the value of positions at the end of the reporting period for trading and clearing (Questions 29 and 30); filers would keep reporting certain trading usage but not end-period position values.
Simplify Monthly Exposure, Turnover, NAICS Reporting
For large hedge fund advisers, the proposal would (1) eliminate reporting of adjusted exposures based on internal methodologies (Question 32), (2) eliminate monthly asset turnover reporting (Question 34), and (3) allow fewer digits of NAICS codes when reporting industry concentration (Question 36).
Streamline Counterparty and Rehypothecation Reporting
The proposal would eliminate the consolidated counterparty exposure table for qualifying hedge funds and instead require completion of a simpler Question 26 table, reporting borrowings to significant counterparties under Questions 42 and 43, and categorizing borrowing entries. It would also eliminate rehypothecation reporting (Question 45).
Remove Private Equity Quarterly Event Reports
Private equity fund advisers would no longer be required to submit quarterly event reports about adviser-led secondary transactions, general partner removals, termination of investment periods, and fund terminations (Section 6).
Narrow Trading Vehicle Identification
Advisers would no longer have to provide identifying information for all trading vehicles; the proposal narrows which trading vehicles must be identified (Question 9).
Cut Volatility Reporting Requirement
The proposal would eliminate Form PF Question 23(c) which currently requires advisers that calculate daily market values to report aggregated volatility information and monthly annualized volatility of returns.
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. This is a solicitation of input rather than an immediate reporting change.
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