The Securities and Exchange Commission and the Commodity Futures Trading Commission have proposed a broad rewrite of Form PF, the confidential filing used to give regulators a window into private funds and the risks they may pose to the financial system. In a joint proposal issued on 20 April, the agencies said the changes are intended to ease compliance costs, particularly for smaller advisers, while preserving the data needed to monitor systemic risk. The SEC said the filing threshold for all advisers would rise from $150 million to $1 billion in private fund assets under management, which would remove many smaller firms from the regime altogether.

The proposal would also sharply lift the bar for large hedge fund reporting, raising the threshold from $1.5 billion to $10 billion in hedge fund assets under management. According to the SEC's release, that would significantly narrow the number of firms required to complete the more detailed hedge fund sections of the form. The agencies also want staff to review the thresholds roughly every five years, a sign that they want Form PF to remain tied more closely to its original systemic-risk purpose rather than capturing smaller managers with limited market impact.

Several reporting obligations would be removed or simplified. The proposal would delete Section 6 altogether, ending quarterly reporting tied to adviser-led secondary transactions, general partner removals and certain fund terminations. It would also let some master-feeder and parallel structures be reported on an aggregated basis, relax look-through requirements for indirect exposures and narrow the definition of "trading vehicles" so that passive entities such as tax blockers and holding companies are not swept in unnecessarily. The SEC and CFTC also want to simplify industry-exposure reporting and trim a number of current and periodic disclosures for large hedge fund advisers.

One area that could see more scrutiny, however, is private credit. The proposal asks for public comment on whether Form PF should include a dedicated section for private credit funds, reflecting both the rapid expansion of the market and the current lack of a clean reporting framework for it. The agencies said comments will be accepted for 60 days after publication in the Federal Register, and the proposal contemplates at least a 12-month compliance transition. That timing matters because the SEC has already delayed the 2024 Form PF amendments, which are now scheduled to take effect in October 2026, and will have to decide how the new proposal fits with that deadline.

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Source: Noah Wire Services