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hflawreport.com

In the first major private fund-related rulemaking since President Trump returned to office, the SEC and CFTC jointly issued proposed amendments (Proposal) to Form PF on April 20, 2026. If adopted in its current form, the Proposal would eliminate filing requirements for certain advisers based on increased reporting thresholds, while streamlining and reducing reporting requirements for many others. The regulators’ goals underlying the Proposal are to reduce the compliance burdens faced by advisers and refocus Form PF on its core purpose: providing data for the monitoring of systemic risks posed by the private funds industry. This article, the first in a two-part series, summarizes the various changes to Form PF outlined in the Proposal and offers analysis from legal experts about its potential impact on hedge and private equity funds. The second article will provide detailed consideration of the revisions that are most applicable to large hedge fund managers. See “Division of Investment Management Staff Discuss Staffing, Operations, Rulemaking and Other Developments” (Jul. 31, 2025).