FACT SHEET

SEC/CFTC Proposed 

Amendments to 

Form PF

U.S. SECURITIES AND EXCHANGE COMMISSION PAGE 1 OF 2

Background

Form PF, adopted by the SEC and CFTC in 2011, provides the SEC and the Financial 

Stability Oversight Council (FSOC) with important, confidential information about the basic 

operations and strategies of private funds. Private funds are pooled investment vehicles that 

are excluded from the definition of “investment company” under the Investment Company 

Act of 1940 and generally include funds commonly known as hedge funds, private equity 

funds, and liquidity funds. FSOC may use information collected on Form PF to monitor and 

assess systemic risk. The SEC and CFTC may use the information collected on Form PF in 

regulatory programs, including examinations, investigations, and investor protection efforts.

Why This Matters

The proposed amendments are designed to enhance FSOC’s ability to monitor systemic risk 

and bolster the SEC’s regulatory oversight of private fund advisers. Since Form PF’s 

adoption, Form PF data show that the value of private fund net assets has more than 

doubled, and the number of private funds has increased by nearly 55 percent, as of the third 

quarter of 2021. The private fund industry’s business practices, complexity of fund 

structures, and investment strategies and exposures also have evolved. Certain investment 

strategies, including credit, digital asset, litigation finance, and real estate strategies, have 

become more common. Similarly, qualifying hedge fund exposures to repurchase 

agreements, reverse repurchase agreements, and U.S. treasury securities have increased. 

Experience with Form PF data also has identified potential ways to improve data quality, 

including when existing reporting may not identify fully potential risks, such as in the reporting 

of certain master-feeder arrangements.

The Securities and Exchange Commission and the Commodity Futures Trading Commission

(CFTC) jointly proposed amendments to Form PF, the confidential reporting form for certain 

SEC-registered investment advisers to private funds, to: 

● Enhance reporting by large hedge fund advisers on qualifying hedge funds;

● Enhance reporting on basic information about advisers and the private funds they 

advise;

● Enhance reporting concerning hedge funds;

● Amend how advisers report complex structures; and

● Remove aggregate reporting for large hedge fund advisers.
FACT SHEET | SEC/CFTC Proposed Amendments to Form PF

U.S. SECURITIES AND EXCHANGE COMMISSION Page 2 of 2

What This Proposal Would Do

The proposed amendments generally are designed to provide greater insight into private 

funds’ operations and strategies, assist in identifying trends, including those that could create 

systemic risk, improve data quality and comparability, and reduce reporting errors.

Enhance Reporting by Large Hedge Fund Advisers on Qualifying Hedge Funds

The proposal would enhance large hedge fund adviser reporting on qualifying hedge funds 

(those with a net asset value of at least $500 million), including how large hedge fund 

advisers report investment exposures, borrowing and counterparty exposure, market factor 

effects, currency exposure reporting, turnover, country and industry exposure, central 

clearing counterparty reporting, risk metrics, investment performance by strategy, portfolio 

correlation, portfolio liquidity, and financing liquidity. 

Enhance Reporting on Basic Information About Advisers and the Private Funds They 

Advise

The proposal would require advisers to report additional information about themselves and 

their private funds, including identifying information, assets under management, withdrawal 

and redemption rights, gross asset value and net asset value, inflows and outflows, base 

currency, borrowings and types of creditors, fair value hierarchy, beneficial ownership, and 

fund performance. 

Enhance Reporting Concerning Hedge Funds

The proposal would remove duplicative questions and require more detailed information 

about hedge fund investment strategies, counterparty exposures, and trading and clearing 

mechanisms. 

Amend How Advisers Report Complex Structures

Currently, Form PF allows advisers to report complex structures either in the aggregate or 

separately, as long as they do so consistently. The practice obscures risk profiles and makes

comparisons of complex structures difficult. The proposal generally would require advisers 

to report separately each component fund in complex fund structures, such as master-feeder 

arrangements and parallel fund structures. 

Remove Aggregate Reporting for Large Hedge Fund Advisers.

Form PF currently requires large hedge fund advisers to report certain aggregated 

information about the hedge funds they advise. Such information can obscure the data about 

hedge funds, including by masking the directional exposures of individual funds. The 

proposal would remove the aggregate reporting requirement.

Additional Information:

The proposed rules will be published on SEC.gov, on CFTC.gov, and in the Federal Register. Comments should 

be received on or before (1) 60 days after issuance and publication on SEC.gov or (2) 30 days after publication 

in the Federal Register, whichever is later.