The SEC and CFTC have proposed a substantial reset of Form PF, raising reporting thresholds and streamlining requirements for private fund advisers while preserving supervisory access to data on the largest and most systemically relevant managers.
The proposed rule would lift the general filing threshold from $150 million to $1 billion in private fund assets under management(AUM) and raise the large hedge fund adviser threshold from $1.5 billion to $10 billion. According to the agencies, the changes would remove many smaller advisers from Form PF filing obligations while continuing to capture more than 90% of private fund gross assets. The agencies are seeking to reduce the operational burden associated with lower-risk filings while retaining access to data on the firms and funds most relevant to financial stability, market functioning and investor protection.Form PF was created after the global financial crisis as part of the Dodd-Frank framework for monitoring risks in private funds. It is a confidential regulatory filing used by the SEC, CFTC and Financial Stability Oversight Council (FSOC) to assess activity across hedge funds, private equity funds, liquidity funds and other private fund structures.
In addition to AUM, Form PF gives supervisors information on leverage, counterparty credit exposure, trading and investment positions, valuation practices, asset types, side arrangements and other data points that can help identify vulnerabilities in non-bank financial intermediation.
The agencies are also proposing to remove or streamline selected requirements. These include certain look-through requirements, performance volatility reporting, counterparty exposure reporting, current reporting for large hedge fund advisers, and quarterly event reporting for private equity fund advisers. At the same time, the proposal would preserve or add mechanisms to identify funds active in private credit, an area that remains high on the supervisory agenda.
The context for the proposal is the continuing scale of the private fund market. SEC private fund statistics for the third quarter of 2025 show 54,392 private funds reporting on Form PF, with $26.9 trillion in gross assets and $16.9 trillion in net assets.
Private funds are embedded in capital markets through activities including credit provision, derivatives activity, Treasury-market participation, securities financing, liquidity management and counterparty relationships with banks and dealers.
Less Data, Better Signal?
The proposal raises a familiar supervisory trade-off: whether regulators can reduce reporting volume while improving the signal value of the data they receive.
The supervisory risk is that smaller advisers can still matter in aggregate, particularly in crowded strategies, niche credit markets or fast-growing private credit segments. Regulators will need confidence that out-of-scope advisers remain visible through other filings, records and supervisory channels.
The agencies’ proposal indicates that advisers below the revised Form PF threshold would still report through Form ADV and remain subject to Advisers Act recordkeeping obligations. That helps preserve baseline visibility, but it does not provide the same risk dataset as Form PF. For supervisors, the effectiveness of the recalibration will depend on whether retained Form PF filings, Form ADV data, examinations and market intelligence are sufficient to identify emerging vulnerabilities.Threshold monitoring becomes a compliance control in its own right. Firms will need systems that can identify when they approach a reporting trigger, show which data was used, and retain an audit trail of the interpretation applied. Rule changes also create change-management obligations. Advisers will need to map old requirements to new ones, retire redundant data fields, preserve required records and update reporting logic without weakening internal oversight.
Supervisors may narrow the reporting population or reduce required data fields, but firms that remain in scope will continue to face high expectations for data governance. Accuracy, timeliness and explainability will remain central to defensible reporting.
The final rule will determine the operational detail, but the direction is toward more targeted collection backed by stronger internal controls.
Subscribe to our newsletter
