SEC, CFTC Propose Raising Form PF Thresholds

On April 20 the Securities and Exchange Commission and the Commodity Futures Trading Commission proposed raising Form PF reporting thresholds to narrow the pool of advisers required to file. The proposal would raise the threshold to $1 billion from $150 million for most private fund advisers and to $10 billion from $1.5 billion for large hedge fund managers. The agencies estimate the changes would continue to cover about 90% of private fund assets.

Form PF, created in 2011, provides confidential information to the SEC, the CFTC and the Financial Stability Oversight Council about private funds’ exposures to industries and countries to help monitor systemic risk. Under the proposal, advisers of funds with between $150 million and $1 billion in assets would no longer be required to file Form PF, a change the agencies say would exempt more than half of current filers. The proposal would retain detailed exposure reporting for funds managed by large hedge fund managers.

The proposal includes a mechanism to identify funds active in the private credit market. Agency officials said the amendments would reduce compliance requirements for many private funds and investment advisers while preserving data regulators consider necessary. A fact sheet released with the proposal provides additional details on the threshold changes and the agencies’ rationale.

In a statement, SEC Chair Paul Atkins wrote, “A key pillar of my agenda is restoring balance to disclosure obligations and reducing the cost of compliance wherever possible.” The agencies wrote that the amended Form PF would still provide regulators with the information needed to monitor systemic risk and to track activity in private credit.

The proposal rolls back disclosure increases adopted during the prior administration. Last year the SEC extended the compliance deadline for enhanced confidential disclosures about portfolio investments and risks until October 2026, and in September the agency delayed enforcement of the 2024 rule. Commissioner Caroline Crenshaw, the agency’s lone Democrat at the time, had argued that the delay would effectively replace the rule; she left the commission in January and both Democratic seats on the SEC remain unfilled.

The CFTC is also operating with reduced membership. Republican Chair Michael Selig is the agency’s lone commissioner. Together the SEC and CFTC are meant to have ten commissioners; the agencies are functioning with four. Officials said the proposal reflects an effort to ease reporting burdens while maintaining access to key market data.

The proposal follows recent strains in private credit markets, where a number of retail-oriented private credit funds experienced rising redemption requests and several managers imposed caps on redemptions. Those developments prompted questions from investors and regulators about liquidity and contagion risks.

Regulators will accept public comments for 60 days after the proposal is published in the Federal Register. The agencies said they expect the amended form to continue capturing data on more than 90% of private fund gross assets.