SEC and CFTC Propose Revisions to Private Fund Reporting, Signaling Policy Shift After Delays

The U.S. SEC and CFTC have proposed new amendments to Form PF, the reporting rules for private funds, reopening policy discussions after multiple compliance delays.

This shift follows a court's decision to strike down a broader SEC rule, positioning Form PF as the main legal tool for regulators to monitor systemic risks within the $30 trillion private fund sector.

The proposed changes aim to strike a balance between gathering essential risk data, such as fund leverage, and easing the reporting burden on the industry, with a final rule anticipated before the October 2026 compliance date.

The U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have jointly proposed a fresh round of changes to Form PF, the confidential reporting form for private funds.

This move is largely a strategic pivot following a significant legal setback. Last year, a federal court struck down the SEC’s ambitious “Private Fund Advisers” rule, which aimed to impose more direct regulations. With that path blocked, regulators are now doubling down on data collection through Form PF. This approach is built on a stronger legal foundation from the Dodd-Frank Act and is the primary channel the Financial Stability Oversight Council (FSOC) uses to monitor potential risks to the entire financial system.

So, what exactly are regulators trying to achieve? First and foremost, they want better visibility into the opaque world of private funds. Statements from the SEC and FSOC have repeatedly highlighted concerns about hidden leverage, particularly in areas like private credit and complex financing arrangements. The 2024 amendments to Form PF were designed to capture this data, but this new proposal suggests a recalibration to get the most critical information without overwhelming the industry.

This proposal also reflects a new era of cooperation between the SEC and CFTC. A recent Memorandum of Understanding (MOU) between the two agencies formalized their commitment to work together, share data securely, and streamline overlapping rules. By issuing a joint proposal, they aim to create a more harmonized reporting system, reducing duplicative burdens for funds that fall under both agencies' jurisdictions.

The journey to this point has been long and bumpy. The major overhaul of Form PF adopted in 2024 has seen its compliance date pushed back multiple times, accumulating a total delay of 568 days to October 1, 2026. These delays, coupled with technical corrections and industry feedback, signaled that the 2024 rules were proving difficult to implement. This new proposal is an acknowledgment of those challenges, reopening the discussion to find a more practical and sustainable path forward.

Form PF: A confidential filing form required for certain private fund advisers to report information about their funds and assets to U.S. regulators.
Systemic Risk: The risk of a collapse in an entire financial system or market, as opposed to risk associated with any one individual entity, group, or component.
FSOC (Financial Stability Oversight Council): A U.S. government organization established by the Dodd-Frank Act to identify and monitor excessive risks to the U.S. financial system.

SEC and CFTC Propose Revisions to Private Fund Reporting, Signaling Policy Shift After Delays

The U.S. SEC and CFTC have proposed new amendments to Form PF, the reporting rules for private funds, reopening policy discussions after multiple compliance delays.

Form PF: A confidential filing form required for certain private fund advisers to report information about their funds and assets to U.S. regulators.
Systemic Risk: The risk of a collapse in an entire financial system or market, as opposed to risk associated with any one individual entity, group, or component.
FSOC (Financial Stability Oversight Council): A U.S. government organization established by the Dodd-Frank Act to identify and monitor excessive risks to the U.S. financial system.