The White House is currently examining a collaborative proposal from the Securities and Exchange Commission and the Commodity Futures Trading Commission that aims to significantly change how private fund advisers report their trading activities related to swaps and security-based swaps. At the core of these proposed modifications lies Form PF, the confidential reporting mechanism employed by private fund advisers since the enactment of the Dodd-Frank Act. These proposed changes would raise the reporting thresholds so substantially that nearly half the current filers could be exempted altogether.
What modifications are proposed to reporting requirements for private fund advisers? The anticipated joint amendment from the SEC and CFTC, set for introduction around April 20, 2026, reveals a considerable increase in the asset management reporting threshold for private fund advisers, rising from $150 million to $1 billion. Additionally, large hedge funds would see their exposure reporting threshold move from $1.5 billion to a staggering $10 billion in assets under management. This change means that only the largest hedge fund firms would need to provide the most detailed level of reporting, considerably reducing the regulatory burden on smaller firms.
Despite the elevated thresholds, the new rules would still encompass 90% of gross private fund assets. Consequently, the majority of private fund advisers would remain under the reporting umbrella, while close to half of current Form PF filers would escape this obligation due to the heightened thresholds.
What is the broader regulatory context influencing this initiative? In December 2025, the CFTC introduced significant revisions to the swap dealer conduct regulations regarding documentation requirements. Similarly, in April 2025, the SEC extended provisions for market players to use CFTC-style reporting for specific security-based swaps until November 5, 2029. The White House review is also considering additional regulatory revisions related to prediction markets, reflecting an inclination towards comprehensive adjustments in financial regulations spanning various asset classes simultaneously.
The implications of these changes for investors, particularly smaller private fund advisers managing between $150 million and $1 billion, could be substantial. The removal of Form PF filing obligations would enable these firms to allocate resources more effectively, rather than toward compliance. Furthermore, as the SEC and CFTC work towards harmonizing requirements, investors should be aware that digital asset-linked derivatives might attract different reporting expectations depending on agency oversight.
What does this mean for the data landscape? Raising the thresholds for reporting obligations may lead to less detailed information being available on mid-sized funds. Regulators are banking on the assumption that the absence of data from the exempted advisers will not impede their overarching oversight objectives, as they still capture a significant portion of private fund assets under this new framework.
Firms involved in both traditional and digital asset derivatives markets should closely monitor the evolution of this proposal. Once the formal proposal is published, the ensuing comment period will present an opportunity for stakeholders to influence the resulting regulations, ultimately determining compliance responsibilities for the immediate future and beyond.