Agencies Propose Form PF Overhaul, Raising Small Adviser Threshold
The U.S. Securities and Exchange Commission and Commodity Futures Trading Commission have jointly proposed amendments to Form PF – the confidential reporting form used to monitor systemic risk in private funds – in a move designed to reduce compliance costs and streamline disclosure obligations for investment advisers.
The proposed amendments would raise filing thresholds and recalibrate reporting requirements, with the agencies saying the changes would still preserve coverage of more than 90% of private fund gross assets — ensuring regulators retain data needed to support the Financial Stability Oversight Council’s systemic risk monitoring.
Key threshold adjustments include raising the small adviser filing threshold from $150 million in private fund assets under management to $1 billion — a change the agencies said is expected to eliminate Form PF filing requirements for nearly half of the advisers currently subject to them — and raising the large hedge fund adviser exposure reporting threshold from $1.5 billion to $10 billion in hedge fund assets under management.
Chairman Atkins emphasized that previous iterations of Form PF had become “overly burdensome,” often distracting advisers from their core investment duties without providing a clear regulatory benefit.
“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 said.
Michael S. Selig, CFTC chairman, echoed these sentiments, noting that the streamlining process is intended to eliminate unnecessary costs for filers. Beyond adjusting thresholds, the agencies plan to simplify several Form PF requirements. The new proposal also introduces a specific method to identify funds active in the private credit market, a growing area of interest for financial regulators.
The agencies are now seeking public input on the proposal. Once the release is published in the Federal Register, a 60-day public comment period will begin.
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