Securities Regulation Daily Wrap Up, INVESTMENT ADVISERS—IAA’s comments to SEC and CFTC support proposed Form PF amendments and suggest others, (Jun 25, 2026)

By Rebecca E. Hoffman, J.D.

The group supports SEC’s and CFTC’s efforts to streamline Form PF and reduce unnecessary burdens while maintaining requirements that serve the purpose of protecting investors and monitoring risk.

The Investment Adviser Association addressed a letter dated June 23 to the SEC and the CFTC, detailing the organization’s reasons for getting behind the commissions’ proposed amendments to Form PF—required filing for investment advisers of private funds—and recommending additional changes “to further streamline Form PF reporting requirements to reduce unnecessary burdens.”

Form PF’s purpose is to collect information that aids the commissions and the Financial Stability Oversight Council in protecting investors from risk.

First, the letter explains that IAA supports increasing the filing threshold from $150 million to $1 billion in private fund assets under management (AUM), noting that the commissions had “appropriately concluded that the existing threshold no longer reflects the size and structure of today’s private fund market and can be modernized without materially diminishing the utility of the data collected.” IAA is also on board with raising the threshold for large hedge fund advisers to $10 billion in hedge fund AUM, and with reviewing thresholds every five years. The letter recommended a parallel increase for large private equity fund advisers and proposed a few possible methods to come to an appropriate level.

Disaggregated option. IAA recommended that aggregated reporting remain an option for master-feeder arrangements and parallel fund structures, so that advisers will not have to report each component separately, as proposed. It observed that aggregated reporting has worked well so far, without hurting efforts to monitor activity and assess potential risks for private funds. The proposal does not “point to any market event, supervisory concern, or systemic-risk assessment that was negatively impacted as a result of the aggregation framework currently in place.”

As for parallel fund structures, having to report on each fund would “be largely duplicative,” and due to their similar features, “[r]equiring separate reporting for each vehicle … multiplies the number of reporting funds and corresponding data points without necessarily providing meaningful additional insight into the overall exposures and activities of the investment program.”

The proposal stated that look-through requirements, adopted during the 2024 amendments, would be operationally difficult to implement, and IAA agreed. These requirements would necessitate collection of information from third parties that would not be reliably available. These requirements should be changed, the letter said, to better comport with advisers’ internal practices. “The proposed amendments to the look-through requirements would reduce operational complexity and reporting costs while continuing to provide regulators with information relevant to their oversight and systemic risk monitoring objectives.”

Trading vehicles, hedge funds, private credit. The commissions recognized that they should narrow the field of trading vehicles that must be individually documented, but IAA recommended that the requirement should be eliminated entirely. “The information most relevant to systemic risk monitoring and investor protection, including a reporting fund’s assets, holdings, exposures, leverage, counterparties, and creditors, is reported elsewhere in Form PF,” the letter observed.

The letter also noted that there are entities technically included within the definition of “hedge fund” in the Form PF context that operate more like traditional private equity or closed-end funds, and therefore either the definition should change, or those funds should not be required to report as hedge funds.

The proposal asked for comment on whether Form PF should include private credit fund reporting, but IAA said that the form collects information on these funds already under private hedge funds or private equity funds, and private credit information is now collected pursuant to other new requirements. The group suggested that the new information should be evaluated before adding yet another requirement that may not be necessary.

Extensions. Another change IAA put on the table is to extend the deadline for a large hedge fund to report a triggering event from 72 hours to four business days, noting that addressing the triggering event itself requires time, attention, and resources.

IAA also recommended a transition period after a final rule is published that considers the time required for FINRA to update its systems. “FINRA should have approximately 12 months following adoption of a final rule to complete this work[, and then] advisers should have no less than 12 months after this before they are required to begin collecting information for the first reporting period covered by the amended form.”

RegulatoryActivity: CFTCNews Enforcement FiduciaryDuties FormsFilings HedgeFundsNews InvestmentAdvisers PrivateEquityNews SECNewsSpeeches