On April 20, 2026, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CTFC and jointly with the SEC, the Commissions) proposed new amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. These new proposed amendments are designed to eliminate certain reporting burdens and would remove reporting obligations for certain advisers entirely. These proposed amendments would reverse earlier amendments enhancing adviser disclosure that were adopted by the Commissions on Feb. 8, 2024, but that have not yet been implemented. For more information on the previously adopted amendments, see Taft’s previous law bulletin.

The new proposed amendments to Form PF primarily would (i) raise the Form PF filing threshold for all advisers from $150 million in private fund assets under management (AUM) to $1 billion; and (ii) raise the reporting threshold for large hedge fund advisers from $1.5 billion in hedge fund AUM to $10 billion. The new proposed amendments would also eliminate or streamline many current Form PF requirements, significantly reducing advisers’ compliance and disclosure burden.

The new proposed amendments follow prolonged concerns with the previously adopted amendments, the compliance date for which was extended three times (from March 12, 2025 to June 12, 2025, from June 12, 2025 to Oct. 1, 2025, and finally from Oct. 1, 2025 to Oct. 1, 2026) and which were described as a “massive burden” by SEC Chairman, Paul Atkins.

Private fund advisers should continue to operate in accordance with the current Form PF because the new proposed amendments are not yet effective and may not be in their final form.