Atkins Commission Proposes Revising Form PF and Requests Comments on Private Credit

Background:

On April 20, 2026, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) jointly proposed amendments to reduce Form PF related regulatory reporting obligations for SEC-registered investment advisers to private funds.
The proposal would eliminate Form PF filing requirements for advisers managing less than $1 billion in private fund assets under management, raise the reporting threshold for large hedge fund advisers from $1.5 billion to $10 billion, and streamline a number of existing Form PF requirements through targeted eliminations and modifications. Notably, the proposal would remove quarterly event reporting for private equity fund advisers.
Although the proposal does not currently contemplate changes to private credit reporting, the SEC’s request for comment suggests that the issue remains atop the SEC agenda.

Key Changes:

	Current Form PF*	Proposed Form PF Change
Elimination of Form PF filing requirements for smaller advisers	Private fund advisers are currently required to file Form PF if they advise at least $150 million in private fund assets under management.	The filing threshold would increase to $1 billion. Advisers below that threshold would no longer be required to file Form PF.
Increase in reporting threshold for large hedge fund advisers	An adviser is currently treated as a large hedge fund adviser at $1.5 billion in hedge fund AUM.	The threshold would increase from $1.5 billion to $10 billion in hedge fund AUM. Advisers below $10 billion would no longer be required to file quarterly Sections 1a, 1b, and 2, or Section 5 qualifying event reports.
Separate reporting for feeder funds	Current Form PF generally requires separate reporting for each component fund in master-feeder and parallel fund structures, subject to limited exceptions. The delayed 2024 amendments would have required separate reporting for every component fund in those structures.	Separate reporting would not be required for a feeder fund if it holds no more than 5% of its gross asset value outside of a single master fund, U.S. Treasury bills, and/or cash equivalents.
Elimination of the “look-through” requirement	Current Form PF includes instructions requiring filers, in certain circumstances, to “look through” a reporting fund’s investments in other private funds and entities. The delayed 2024 amendments would have made those instructions more detailed and prescriptive.	The “look-through” requirement would be eliminated. Advisers instead could use reasonable estimates of indirect exposure consistent with their internal methodologies.
Narrowing of trading vehicle identification requirements	If a reporting fund holds assets, incurs leverage, or conducts trading or other activity through a trading vehicle, the adviser must currently provide identifying information for each such vehicle.	Identification would be required only for trading vehicles disclosed in Section 7.B of Schedule D to Form ADV or referenced in responses to Questions 27, 28, 42, 43, and 44 of Form PF.
Removal of performance volatility reporting	Question 23(c) under the delayed 2024 amendments would required additional performance-related reporting where the adviser calculates daily market values for any position in the reporting fund’s portfolio.	Question 23(c) would be deleted for all filers.
Elimination of certain trading and clearing disclosures	Questions 29 and 30 currently require filers to report their use of trading and clearing mechanisms, including both trading activity during the reporting period and period-end position values.	Question 29(ii) and Question 30(b) period-end reporting would be eliminated for all filers.
Streamlining of adjusted exposure reporting	Question 32(b)(2) under the delayed 2024 amendments would have required large hedge fund advisers to report adjusted exposure by sub-asset class.	Question 32(b)(2) would be deleted for large hedge fund advisers. In addition, the reference to “counterparties” would be removed from Question 32(b)(1).
Removal of portfolio turnover reporting	Question 34 under the delayed 2024 amendments would have required monthly turnover reporting by asset class for each hedge fund, including equities, corporate debt, sovereign debt, derivatives, and foreign exchange.	Question 34 would be deleted in its entirety for large hedge fund advisers.
Simplified industry concentration reporting	Filers responding to Question 36 must currently report industry exposure using six-digit NAICS codes.	Question 36 would permit reporting using less granular NAICS coding.
Removal of certain reference asset exposure questions	Questions 39 and 40 currently require detailed reporting on reference asset concentration and threshold-based position exposure.	Questions 39 and 40 would be deleted for large hedge fund advisers, with more streamlined exposure reporting added to Section 5, Item B.
Simplification of counterparty exposure reporting	Large hedge fund advisers currently must report, in a consolidated counterparty exposure table, aggregate month-end data on borrowing, collateral received, lending, and posted collateral across all counterparties.	The detailed borrowing table would be eliminated. More streamlined reporting would instead be incorporated into Question 26 and borrowing-related disclosures under Questions 42 and 43.
Removal of rehypothecation reporting	Question 45 currently requires qualifying hedge funds to report the total amount of counterparty-posted collateral and the amount rehypothecated.	Question 45 would be deleted.
Changes to Section 5 extraordinary event reporting	Large hedge fund advisers currently must report Section 5 events as soon as practicable, but no later than 72 hours after occurrence. Covered events include significant drawdowns, margin and default events, prime broker changes, operational events, and certain redemption-related events.	The filing deadline would be revised to a full 72 hours, replacing the “as soon as practicable” standard. Item D (margin default) would be deleted, Item G would be narrowed to core operational events, and the Item I inability-to-pay-redemptions prong would be eliminated.
Elimination of quarterly event reporting for private equity fund advisers	Private equity fund advisers currently must file quarterly event reports covering adviser-led secondary transactions, GP removals, termination of investment periods, and fund terminations.	Quarterly event reporting for private equity fund advisers would be eliminated.
Corrections and miscellaneous revisions	The current form includes certain inconsistent headings and conflicting instructions.	The proposal includes minor technical, conforming, and clarifying revisions to improve usability and consistency.
Request for comment on private credit reporting	Private credit is listed as an available strategy option in the dropdown menu for Question 25.	The proposal requests comment on whether a dedicated private credit reporting section should be added to Form PF. Note that private credit is still an available strategy option listed in the drop-down menu in Question 25.

^{*Refers to FormPF as amended jointly by SEC-CFTC, on February 8th 2024. The changes have not yet been implemented.}

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