SEC and CFTC Jointly Propose Amendments to Reduce Private Fund Reporting Burdens

The SEC and CFTC have jointly proposed amendments to Form PF aimed at reducing reporting burdens for private fund advisers while preserving regulators’ ability to monitor systemic risk.

Form PF is a confidential filing required for certain SEC-registered investment advisers to private funds. The data supports oversight by the Financial Stability Oversight Council (FSOC) and informs investor protection efforts.

Key Proposed Changes

• Higher Filing Threshold: Increase from $150 million to $1 billion in private fund AUM, removing filing requirements for nearly half of current filers.
• Revised “Large Hedge Fund Adviser” Threshold: Increase from $1.5 billion to $10 billion in hedge fund AUM.
• Streamlined Reporting: Eliminate or simplify several data requirements to reduce compliance burden.
• Private Credit Identification: Introduce a method to better track funds active in private credit markets.

Regulators expect to retain visibility into more than 90% of private fund assets despite the reduced scope.

What This Means for Advisers

This proposal is not final, so don't adjust compliance programs yet. If adopted, the amendments would significantly reduce reporting obligations, particularly for smaller advisers, while maintaining focus on larger firms.

Advisers should assess whether they would remain subject to Form PF and consider providing feedback during the comment period.

Next Steps

The proposal will be published in the Federal Register, with a 60-day public comment period to follow.

Bates Group supports private fund advisers in navigating evolving regulatory requirements with practical, tailored solutions. Our Complaince team will continue to monitor this development, and we are happy to engage with the industry on its potential impact. Connect with us today to join the conversation.