The Joint Data Proposals

On February 8, 2024, the U.S. Securities and Exchange Commission and the U.S. Commodity Futures Trading Commission jointly adopted changes to the systemic risk reporting template to be completed by registered investment advisers that advise private funds -- Form PF.  The changes adopted were not siginifcantly revised from what was proposed and constitute a nearly full re-write of the sections of the form that affect all filers and large hedge fund advisers in particular.  These revisions are the third set of changes in the last year to the Form PF adopted by the SEC and affect the parts of the Form that are jointly controlled by the SEC and CFTC.

The the most substantive and challenging of the changes to the form are in the following areas:

• Treatment of master feeder funds: See revised Instructions 5, 6 and 7.
• Look throughs and aggregation: See revised Instructions 7 and 8, Questions 32, 33, 35, 36 and 47 and the revised definitions that include specific look through requirements as well.
• Fund performance reporting: See Question 23.
• Counterparty and creditor disclosures for all funds other than qualifying hedge funds:  See Questions 26, 27 and 28.
• Disclosure of the monthly aggregate reporting fund exposures (long and short) by sub-asset class: See Question 32.
• Currency exposure: See Question 33.
• Netted exposures: See Question 39.
• Detailed reporting regarding reference assets: See Question 40.
• Counterparty and creditor disclosures for qualifying hedge funds:  See Questions 41, 42, 43 and 44.
• Monthly and quarterly performance reporting: See Question 49.

Filers will have 365 following the publication of the adopting release in the Federal Register to update their reporting systems in line with the altered reporting requirements.

A full summary of the new requirements and the differences between what was proposed and what was ultimately adopted can be accessed by AIMA members here.

Note: On September 17, 2025, the SEC and CFTC further extended the effective/compliance date for the joint data changes to October 1, 2026.

April 2026 Streamlining Proposal

On April 20, 2026, the U.S. Securities and Exchange Commission (“SEC”) and the U.S. Commodity Futures Trading Commission (“CFTC”) jointly published a proposed rulemaking to amend Form PF, with the aim of streamlining private fund systemic risk reporting requirements (the “Proposed Requirements”).  Terms used in this summary have the meanings ascribed to them in the proposed Form PF.

The Proposed Requirements include the following key changes to Form PF:

Thresholds

• Increasing the filing threshold for all filers from $150 million to $1 billion in private fund asset under management. (General Instruction 1)
• Raising the reporting threshold for large hedge fund advisers from $1.5 billion to $10 billion in hedge fund assets under management. (General Instruction 3)

Reporting obligations for all filers

• Eliminating the requirement to separately report feeder funds with only de minimis holdings other than its investment in a single master fund, U.S. Treasury bills and/or cash and cash equivalents. (General Instruction 6)
• Removing certain prescriptive “look-through” requirements, allowing advisers to report indirect exposures using reasonable estimates aligned with internal methodologies and service provider conventions. (General Instructions 7 and 8 and conforming amendments to certain questions and definitions)
• Narrowing the scope of the types of trading vehicles that must be identified. (Question 9 and General Instruction 7)
• Eliminating certain performance volatility reporting requirements, including aggregated calculated values, monthly annualized return volatility and data derived from daily rates of return. (Question 23(c) and General Instruction 15)
• Removing the requirement to report the value of positions at the end of the reporting period. (Questions 29 and 30)

Reporting obligations for large hedge fund advisers

• Eliminating one of the required reporting methods for monthly adjusted exposures of qualifying hedge funds. (Question 32)
• Eliminating the requirement for large hedge fund advisers to report monthly turnover by asset class. (Question 34)
• Allowing filers to elect to use fewer digits of North American Industry Classification System (NAICS) codes when reporting industry exposure. (Question 36)
• Eliminating reporting on monthly concentrated exposures to reference assets, instead incorporating a streamlined exposure measure into the existing extraordinary loss current reporting trigger. (Questions 39 and 40, and Section 5, Item B)
• Removing the consolidated counterparty exposure table, instead allowing large hedge fund advisers to report simplified exposure data in Question 26, disclose the value of the reporting fund’s borrowings and types of creditors in Question 18, disclose borrowings to significant counterparties in Questions 42 and 43, and categorize significant borrowing entries within Question 42. (Questions 41 and 42, and conforming amendments to Questions 18, 26, 43, and the Glossary of Terms)
• Eliminating the requirement to report the amount of collateral posted by counterparties that may be or has been rehypothecated. (Question 45)
• Modifying current reporting triggers by removing the requirement to report “as soon as practicable”. (Section 5)

Current reporting obligations for large hedge fund advisers

• Deleting reporting requirements related to margin defaults or failures to meet calls for margin, collateral, or equivalents within 72 hours. (Section 5, Item D)
• Changing the requirement to report certain operational events involving significant disruptions to a fund’s critical operations within 72 hours by removing the obligation to report “as promptly as practicable” and by amending the definition of “critical operations” to remove the trigger prong regarding events related the operation of the reporting fund in accordance with the Federal securities laws and regulations. (Section 5, Item G and the Glossary of Terms)
• Removing the requirement to report when a fund is unable to meet redemption requests within 72 hours, while retaining reporting for prolonged redemption suspensions. (Section 5, Item I)

Current reporting obligations for large private equity fund advisers

• Eliminate quarterly event reporting requirements for private equity fund advisers. (Section 6 and cross references in General Instructions 1, 3 and 12)

The Proposed Requirements also include a variety of other small corrections and revisions.

In addition to proposing the changes above, the SEC and CFTC have posed a series of questions regarding whether and how to modify the information that advisers report regarding private credit funds.

The Proposed Requirements include a 12-month transition period beginning once any new requirements are adopted, but the fate of the requirements due to be complied with as of October 1, 2026 remains an open question.

Comments are due on or before June 23, 2026.

If there are questions regarding these new requirements, please contact Jennifer Wood.

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  Jennifer Wood

  Managing Director, Global Head of Asset Management Regulation & Sound Practices