Form PF Reporting: Thresholds, Deadlines and the July 2027 Form Switch

Form PF reporting is the confidential return an SEC-registered investment adviser files on its private funds once the adviser and its related persons hold at least $150 million in private fund assets under management on the last day of a fiscal year. The duty sits in rule 204(b)-1 under the Investment Advisers Act of 1940 (17 CFR 275.204(b)-1). The form itself is designated 17 CFR 279.9 and is a joint form of the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) for its first two sections. On 3 September 2026 the two Commissions published a joint final rule moving the compliance date for the February 2024 Form PF amendments to 1 July 2027, the fourth postponement of a package first due on 12 March 2025.

Until that date, filings due before 1 July 2027 must continue to be filed through Classic IARD/PFRD under the Form PF requirements applicable before the 2024 joint amendments; the amended version is not available for submission before its compliance date. The reference copy the SEC posts already shows the amended form, and an April 2026 proposal would lift the filing threshold to $1 billion. Three layers are therefore live at once, and every submission has to answer four questions: is the adviser in scope, which sections apply, which clock runs, and which version of the form the Private Fund Reporting Depository (PFRD) expects.

The form spells out the consequence: failure to update Form PF as the instructions require is a violation of SEC and, where applicable, CFTC rules and could lead to revocation of the adviser’s registration.

Related reading: AIFMD II Annex IV Reporting Changes

The legal basis of Form PF reporting: section 204(b), rule 204(b)-1 and 17 CFR 279.9

Form PF exists because sections 404 and 406 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 amended the Advisers Act to require private fund advisers to file reports. Congress authorised the SEC to require the information it judges necessary and appropriate in the public interest and for the protection of investors, or for the assessment of systemic risk. The legal chain has three links:

• Statute: section 204(b) of the Advisers Act (15 U.S.C. 80b-4(b)), the collection power the form itself cites.
• Rule: 17 CFR 275.204(b)-1, which sets the $150 million filing condition, electronic filing, the filing fee, the annual and more frequent update duty, the temporary hardship exemption, and the definitions of assets under management and private fund assets.
• Form: 17 CFR 279.9 names Form PF, and the form’s text is published by the SEC as form SEC 2048 and attached to the adopting releases. It does not appear in the Code of Federal Regulations.

That last link catches anyone who prints the CFR expecting the rulebook. The thresholds for the large adviser tiers, the 60-day and 15-day quarterly clocks, the section map and the defined terms all live in the form’s General Instructions and its Glossary of Terms. For most working obligations, the text to cite is the form.

The CFTC side is narrower than the “joint form” label suggests. The 2026 extension release records that Form PF is joint only for Sections 1 and 2. An adviser also registered with the CFTC as a commodity pool operator (CPO) or commodity trading adviser (CTA) files with the SEC, and CFTC rule 4.27(d) treats that dual registrant as having filed Form PF with the CFTC for the purpose of any enforcement action over a false or misleading statement of material fact. The signature block says the same thing from the other side: where Section 1 or 2 is filed under CFTC rule 4.27, a material misstatement or omission is a violation of section 6(c)(2) of the Commodity Exchange Act.

Confidentiality is built in. The form states that the SEC does not intend to make public any information identifiable to a particular adviser or private fund, although it may use Form PF information in an enforcement action. The data feeds the Financial Stability Oversight Council’s (FSOC) monitoring of systemic risk in the private fund industry, and the SEC and CFTC may use it in examinations, investigations and investor protection work. That design separates Form PF from US reporting regimes built for publication, such as the municipal trade data in our RTRS reporting guide.

Who must report on Form PF: the $150 million test and the large adviser tiers

Instruction 1 of Form PF and paragraph (a) of rule 204(b)-1 set three cumulative conditions. An adviser files if it:

• is registered or required to be registered with the SEC as an investment adviser (a CPO or CTA is caught only if it is also SEC-registered or required to be);
• advises one or more private funds; and
• together with its related persons had at least $150 million in private fund assets under management on the last day of its most recently completed fiscal year.

A private fund is an issuer that would be an investment company under the Investment Company Act of 1940 but for the exclusions in section 3(c)(1) or section 3(c)(7). Private fund assets are the adviser’s regulatory assets under management, determined under Item 5.F of Form ADV, that are attributable to private funds. In my reading the threshold figure should therefore trace straight back to the Form ADV number, because the rule defines one by reference to the other. The form itself names an exempt reporting adviser as an example of an adviser that is not required to file.

Three carve-outs change who counts:

• Separately operated related persons. Their regulatory assets under management can be left out of the threshold tests (Instruction 5). Funds advised by other related persons count as the adviser’s own, and related persons may file a single Form PF if they identify each other in Question 1.
• Non-US advisers. An adviser whose principal office and place of business is outside the United States may disregard any private fund that, during its last fiscal year, was not a United States person, was not offered in the United States and was not beneficially owned by any United States person. All three limbs must hold.
• Subadvised funds. Only one adviser files for each private fund: the adviser that filed Form ADV Section 7.B.1 for it. If that adviser is not required to file Form PF and one or more other advisers to the fund are, another adviser must file for the fund.

Beyond the entry test, the tiers below decide how much of the form an adviser completes:

A qualifying hedge fund is a hedge fund with net asset value of at least $500 million, alone or combined with its feeder funds, parallel funds and dependent parallel managed accounts, as of the last day of any month in the fiscal quarter immediately preceding the most recently completed fiscal quarter. Under the amended form, a separate Section 2 is also required for each parallel fund in a structure that together comprises a qualifying hedge fund, and for the master fund of a master-feeder arrangement that does. The version filed until 1 July 2027 lets an adviser report such a structure in the aggregate, consistently across the form, with a single Section 2b for its reporting fund.

The fund categories come from the Form PF glossary, whatever the offering documents call the fund. A hedge fund is any private fund, other than a securitized asset fund, that meets any one of three tests: an adviser or related person may be paid a performance fee or allocation calculated by taking unrealized gains into account, other than a fee or allocation whose calculation may take unrealized gains into account solely to reduce it to reflect net unrealized losses; the fund may borrow more than half its net asset value (including committed capital) or have gross notional exposure above twice its net asset value; or the fund may sell securities short or enter into similar transactions, other than to hedge currency exposure or manage duration. Each test asks what the fund may do. The 2024 adopting release gives the consequence: a fund held out as private equity whose documents permit some short selling, but which has not shorted in the past 12 months, is reported as a hedge fund with zero short exposure.

A private equity fund is defined residually, as a private fund that is not a hedge fund, liquidity fund, real estate fund, securitized asset fund or venture capital fund and that does not give investors redemption rights in the ordinary course. Commodity pools are treated as hedge funds for Form PF purposes.

What the report contains: Sections 1 to 7, data conventions and fund structures

The SEC’s reference copy lays the form out in seven sections, each tied to a tier:

• Section 1a, all filers: identifying information about the adviser and the related persons it reports for, and information about the assets of the private funds it advises.
• Section 1b, all filers, for each private fund: identifying information; assets, financing and investor concentration; and performance, which may be reported as a time-weighted return or as a money-weighted return such as an internal rate of return.
• Section 1c, for each hedge fund: further information about each hedge fund the adviser advises.
• Section 2, large hedge fund advisers, for each qualifying hedge fund: exposures and trading, risk metrics and performance, financing, and investor information.
• Section 3, large liquidity fund advisers, for each liquidity fund: operational information, assets, financing, investors, portfolio information, disposition of portfolio securities and parallel money market funds.
• Section 4, large private equity fund advisers, for each private equity fund: strategy by share of deployed capital, each country (by ISO code) to which portfolio company investments represent 10% or more of net asset value, fund-level borrowing and portfolio company financing, and portfolio company investment exposures.
• Section 5: the current report for large hedge fund advisers on qualifying hedge funds, Items A to J.
• Section 6: the quarterly event report for advisers to private equity funds, Items A to D.
• Section 7: the temporary hardship exemption request.

The Section 2 description follows the amended form. The version filed until 1 July 2027 splits large hedge fund reporting into Section 2a, aggregate information across all of the adviser’s hedge funds, and Section 2b, reporting per qualifying hedge fund. The 2024 amendments delete Section 2a and redesignate Section 2b as Section 2. The adopting release explains that the aggregated data had proved less meaningful for analysis, more burdensome to report and at times inconsistent with the per-fund figures. Question numbers move with it, so any mapping keyed to question numbers has to be versioned.

Instruction 15 of the reference copy sets the data conventions:

• Information is given as of close of business on the data reporting date, and monthly or quarterly figures as of close of business on the last calendar day of the month or quarter. For an annual filer the data reporting date is the last calendar day of the most recently completed fiscal year.
• Monetary values are in US dollars, rounded to the nearest thousand, converted at the exchange rate for the applicable date. Transactional data covering a period is converted at the rates on the transaction dates.
• Percentages are entered as percentages, not decimals, rounded to the nearest hundredth of one percent. Other numbers are rounded to the nearest whole number.
• Long and short positions are not netted. For derivatives other than interest rate derivatives and options, value means gross notional value; interest rate derivatives use the 10-year bond equivalent; options use delta-adjusted notional value.
• Other investments are valued at market value or, without a readily available market value, at fair value. Borrowings where the fund is the debtor are valued as reported internally and to current and prospective investors.

An adviser may use its own methodologies and its service providers’ conventions if the results match its internal and investor reporting and are applied consistently, and it may explain them in Question 4. The 2024 amendments changed several of these conventions, so a data mapping built for the version filed until 1 July 2027 has to be versioned: percentages move from the nearest whole percent to the nearest hundredth of one percent, interest rate derivatives are valued as a 10-year bond equivalent under a new glossary definition expressed in US dollars, and monetary values use the exchange rate for the applicable date, or the transaction-date rates for transactional data.

Aggregation for the threshold tests and aggregation for reporting follow separate rules. For thresholds, private funds in the same master-feeder arrangement or parallel fund structure are aggregated, and a dependent parallel managed account is added to the largest private fund it relates to. For reporting, the amended form requires a separate report for each component fund of a master-feeder arrangement or parallel fund structure, except a disregarded feeder fund that invests only in a single master fund, US Treasury bills and/or cash and cash equivalents. The amended Instruction 7 standardises the treatment of investments in other private funds across the Form PF threshold tests. The prior form generally allowed such investments to be disregarded consistently for reporting-threshold purposes, but the 2024 adopting release states that they were already required to be included when determining whether the adviser met the basic Form PF filing threshold. Under the reference copy, a private fund that invests 80% or more of its assets in the equity of other private funds, and otherwise holds only cash, cash equivalents and currency-hedging instruments, completes only Section 1b.

Trading vehicles get their own rule in the amended form. The adviser identifies each trading vehicle through which a reporting fund holds assets, borrows or trades (Question 9) and reports the fund and the vehicle on an aggregated basis, looking through to the vehicle’s holdings in proportion to the fund’s ownership.

One dependency sits outside the form entirely. Each private fund needs a private fund identification number, and that number can only be obtained by filing Form ADV. If a Form PF quarterly update falls due before the adviser’s next annual Form ADV amendment, Instruction 10 requires an other-than-annual Form ADV amendment, completing all of Section 7.B.1 for the new fund, to generate the number first.

Form PF deadlines: annual updates, quarterly updates, 72-hour current reports and event reports

Rule 204(b)-1(e) requires an updated Form PF at least annually and more often where the instructions require it; Instruction 9 supplies the clocks:

• Annual update, for advisers other than large hedge fund and large liquidity fund advisers: within 120 calendar days after fiscal year end. For a 31 December year end that is 30 April, or 29 April in a leap year.
• Quarterly update, large hedge fund advisers: within 60 calendar days after quarter end.
• Quarterly update, large liquidity fund advisers: within 15 calendar days after quarter end. An adviser in both tiers files liquidity fund data within 15 days and hedge fund data within 60 days.
• Current report, Section 5: as soon as practicable, and no later than 72 hours after the event occurs or after the adviser reasonably believes it occurred.
• Private equity event report, Section 6: within 60 calendar days after the end of the fiscal quarter in which the reporting event occurred.
• Temporary hardship: the request is due no later than one business day after the electronic filing was due, and the electronic filing no later than seven business days after it was due.

Which quarter the 60-day and 15-day clocks run from depends on the version of the form. The 2024 adopting release describes the existing rule as fiscal-quarter reporting for large hedge fund and large liquidity fund advisers. It also records that, on Form ADV data as of December 2022, 99.6 percent of private fund advisers already effectively filed on a calendar basis because their fiscal quarters or years end on calendar quarter or year ends. For a large hedge fund adviser on calendar quarters, the 60-day clock lands on 30 May, 29 August, 29 November and 1 March (29 February in a leap year). A large liquidity fund adviser’s 15-day clock lands on 15 April, 15 July, 15 October and 15 January. The instructions state the periodic deadlines in calendar days and say nothing about weekends or holidays.

The amended form requires quarterly filers to report on a calendar quarter basis. An adviser whose fiscal year does not end on a calendar quarter end files a quarterly update within 60 days (15 days for liquidity funds) after the end of the next calendar quarter after its fiscal year end. It may first file covering only its hedge funds, or only its liquidity funds, provided it amends within 120 days of fiscal year end to update its other private funds. Large hedge fund and large liquidity fund advisers file no separate annual update; the quarterly update for the quarter after fiscal year end carries it.

On the switchover, the 2024 adopting release says advisers do not move to the new timing until the first calendar quarter-end filing for the first full quarterly reporting period after the compliance date. Neither the rule, the form nor the 2026 extension release translates that sentence into a named quarter for the 1 July 2027 date. The SEC staff Form PF FAQ, last reviewed or updated on 20 August 2025, still carries worked dates built on the superseded October 2025 compliance date, so its examples cannot be read across without adjustment.

Section 5 runs on hours. The 72-hour period starts at the event, or when the adviser reasonably believes the event occurred, and the adviser answers to the best of its knowledge on the report date. Items B to I define the triggers for a qualifying hedge fund:

• Item B, extraordinary investment losses: a 10-business-day holding period return of minus 20% or worse on any business day.
• Item C, margin increase: margin, collateral or equivalent posted rises over a rolling 10-business-day period by 20% or more of the fund’s average daily aggregate calculated value.
• Item D, notice that the fund is in default on a call for margin, collateral or an equivalent, resulting in a deficit it will not be able to cover or address by adding funds, or a determination that the fund is unable to meet a call for increased margin, collateral or an equivalent.
• Item E, counterparty default: a counterparty fails to meet a call for margin, collateral or an equivalent, or to make any other payment, in the time and form contractually required (taking into account any contractually agreed cure period), where the amount involved exceeds 5% of the fund’s aggregate calculated value.
• Item F, a prime broker terminating or materially restricting its relationship with the fund, in whole or in part, in markets where that prime broker remains active, or a termination of the relationship by either the fund or the prime broker where a termination event under the prime brokerage or related agreements was activated within the last 12 months.
• Item G, an operations event: a significant disruption or degradation of the fund’s critical operations, whether at the fund, the adviser or a service provider.
• Item H, cumulative withdrawal or redemption requests of 50% or more of the most recent net asset value, after netting subscriptions and contractually committed contributions.
• Item I, inability to pay redemption requests, or a suspension of redemptions lasting more than 5 consecutive business days.

The carve-outs sit inside the item text. Where a contractual cure period exists, an Item D report is not due until the cure period expires, unless the fund does not expect to meet the call within it. A disputed margin call does not require an Item D report if the fund has enough assets to meet the greatest of the disputed amounts. Item B reports are not filed for overlapping 10-business-day periods, and a continuing margin increase under Item C does not generate another report until the next 10-business-day period begins. Termination events isolated solely to the prime broker’s own financial state, activities or other conditions do not count for Item F, while a change of terms that significantly limits the fund’s ability to operate under the original agreement, or significantly impairs its ability to trade, counts as a material restriction. If difficulties caused by an operations event prevent timely filing, Item G allows the current report to be filed as soon as practicable, with the difficulty explained in Item J.

Section 6 is quarterly, but only when something happens. The General Instructions set the deadline at 60 calendar days after the end of each fiscal quarter, while the Section 6 preamble in the reference copy refers to the end of each calendar quarter. Footnote 16 of the 2024 adopting release settles the point for the amendments: the calendar-quarter change does not apply to private equity event reports, which run from the applicable fiscal quarter. The two triggers are the closing of an adviser-led secondary transaction (Item B), meaning a transaction initiated by the adviser or a related person that offers fund investors the choice to sell their interests or to convert or exchange them for interests in another vehicle the adviser or a related person advises, and notice that fund investors have removed the adviser or its affiliate as general partner, elected to terminate the investment period or elected to terminate the fund, as the fund’s governing documents contemplate (Item C). No report is filed for a quarter without an event, and an event already reported is not reported again.

Three one-off filings sit alongside the cycle. An initial report is due by the last day on which the next update would have been timely had the adviser filed before, and no filing is required for any fiscal quarter or year that ended before the adviser’s registration became effective. A large hedge fund or large liquidity fund adviser that drops out of its tier makes a transition filing (Item A of Section 1a, with the transition box checked) no later than the date its next quarterly update would have been due. An adviser that is no longer required to file makes a final filing on the same basis.

Submission of Form PF: PFRD on IARD, fees, signatures and file formats

Rule 204(b)-1(b) requires electronic filing through the Form PF filing system on the Investment Adviser Registration Depository (IARD). The 2026 extension release describes that system as the Private Fund Reporting Depository, a subsystem of IARD. Instruction 12 directs questions about filing through it to the Financial Industry Regulatory Authority (FINRA). The PDF on sec.gov is a reference copy only, and the SEC states on its cover that a completed printout cannot satisfy a filing obligation.

The mechanics that decide whether a filing counts:

• Filing moment: a Form PF is considered filed with the SEC upon acceptance by the filing system (rule 204(b)-1(c)).
• Fee: the adviser pays the operator of the filing system a filing fee under the schedule published at sec.gov/iard and iard.com. The operator will not accept the filing, so it is not filed, until the fee is paid, and no portion of the fee is refundable.
• Scope of a current or event report: a large hedge fund adviser filing a Section 5 report files only Section 5, and an adviser filing a Section 6 report files only Section 6.
• Signature: a typed name, with no notarisation, given by the person the adviser’s form of organisation requires. That means the sole proprietor, a general partner, an authorised principal officer, a managing member or authorised person, or, for a separately identifiable department or division of a bank, a principal officer directly engaged in the advisory activities. For any other form of organisation, the signatory is an authorised individual who participates in managing or directing the adviser’s affairs. Where related persons file together, the signatories collectively need authority for all of them.
• Formats: the SEC staff FAQ records that the amended form was made available through FINRA Gateway in January 2025 and that a draft XML schema for it was released that month. Neither the rule, the form instructions nor the staff FAQ specifies a file-naming convention or an XBRL taxonomy for Form PF.

The temporary hardship exemption covers unanticipated technical difficulties that prevent a timely filing through the system. It extends the electronic deadline by seven business days, and the report itself still goes through PFRD. The request consists of Item A of Section 1a and Section 7, with the hardship box checked, filed no later than one business day after the filing was due.

The amended Instruction 14 in the reference copy allows the request to be mailed to the SEC’s Investment Adviser Regulation Office or emailed as a signed PDF to FormPF@sec.gov. The pre-2024 Instruction 14, in the version of the form filed until 1 July 2027, provides only for a paper request, with one manually signed original and one copy sent by mail. Rule 204(b)-1(f)(4) treats the request as filed on the earlier of its postmark date or the date the SEC receives it. The general Advisers Act hardship exemptions in rule 203-3 do not apply to Form PF.

Validation of Form PF filings: acceptance, rejection and the published data-quality record

FINRA, as operator of PFRD, publishes Form PF schema documentation, release notes and filing guidance, and states that XML uploads must satisfy the same completeness checks and business rules applied to the web form. The SEC rule, Form PF instructions and staff FAQ publish no single numbered validation-rule or error-code catalogue. At the rule-and-form level, three filing gates are explicit:

• Acceptance: a submission the filing system has not accepted has not been filed.
• Fee: an unpaid fee blocks acceptance.
• Completeness: the General Instructions warn that failing to follow the instructions, to complete the form properly or to pay required fees may result in the filing being delayed or rejected.

For errors inside accepted filings, the 2024 adopting release is the fullest public record, because it explains most amendments by the problems SEC staff found in the data:

• Identifiers: advisers reporting RSSD IDs as LEIs made it harder for staff to link data efficiently. The amended LEI definition bars any non-LEI substitute where an LEI has been assigned, and asks for LEIs for the adviser and its related persons where they have one.
• Market factor omissions: the existing wording let an adviser omit a response where it had tested a similar, but not identical, market factor. The amended form requires every listed market factor, with zero reported for factors to which the portfolio is not exposed.
• Aggregation: turnover reporting on US Treasury securities was so aggregated that staff reviewing the March 2020 market events could not get a complete picture of hedge fund activity in long Treasuries and Treasury futures. The amended Section 2 reports turnover per fund and at a finer granularity.
• Timing: fiscal-quarter reporting could delay the complete calendar-quarter data set from large hedge fund advisers by as much as four months, which drove the calendar-quarter change.

Corrections run through Instruction 16. An adviser that discovers information was inaccurate when filed re-files with the amendment box checked in Section 1a, Section 5 or Section 6. It is not required to update information it believed in good faith was a proper response on the filing date, even if the figure is later revised for recordkeeping, risk management or investor reporting, such as an estimate refined after an audit. A large hedge fund or large liquidity fund adviser that meets its fourth-quarter obligations with an initial filing followed by the permitted amendment is not treated as affirming its answers for one fund merely by updating another. The staff FAQ adds that, once the compliance date passes, amendments and corrections to earlier filings are also made on the amended form, with corrections to redesignated questions entered under the new question numbers.

Caveats and interactions: transitional wording, commodity pools and the EU overlap

FINRA’s current PFRD instructions state that filings due before 1 July 2027 must be filed in Classic IARD/PFRD. The amended Form PF is available in FINRA Gateway for preparation. FINRA published the final amended Form PF XML schema on 2 March 2026 and maintains a QA test environment through June 2027; the production XML schema is scheduled for deployment on 1 July 2027.

Proportionality is built mainly into the tiers; outside them, the fund-of-funds rule in Instruction 7 limits a qualifying fund of funds to Section 1b. Rule 204(b)-1 contains no waiver provision; its only relief mechanism is the temporary hardship exemption, and rule 204(b)-1(f)(5) shuts out the general Advisers Act hardship provisions.

Commodity pools carry a threshold wrinkle. A commodity pool that is not a private fund may be treated as a private fund for Form PF, but it is not required to be included when determining whether the adviser crosses a reporting threshold. If such a pool is a qualifying hedge fund and the adviser otherwise reports in Section 2, the pool must be reported in Section 2.

For a US adviser that also manages or markets funds in the European Union, the EU return is a separate obligation, although the amended Form PF asks in Question 6 whether each reporting fund operates as an AIF, a term it defines by reference to Directive 2011/61/EU, and in which countries. Each regime computes exposure its own way. Form PF values derivatives under its own Instruction 15, while the EU return applies its own methodology, set out in our AIFMD II Annex IV leverage calculation template. A suspension of redemptions works the same way: the Item I test (more than 5 consecutive business days) stands apart from anything the manager does under the AIFMD II liquidity management tools regime.

Changes to Form PF: 2023 event reporting, the 2024 amendments, the 1 July 2027 date and the 2026 proposal

The rulemaking record since 2023:

• 3 May 2023: SEC-only amendments (Release IA-6297, 88 FR 38146, 12 June 2023) add Section 5 current reports and Section 6 private equity event reports, amend Section 4 for large private equity fund advisers and redesignate the old Section 5 as Section 7. Sections 5 and 6 took effect on 11 December 2023; the amendments to existing sections took effect on 11 June 2024.
• July 2023: the SEC amends Section 3 as part of its money market fund reforms, effective and compliant from 11 June 2024.
• 8 February 2024: joint SEC and CFTC amendments (Release IA-6546, 89 FR 17984, 12 March 2024), with a single effective and compliance date of 12 March 2025.
• 29 January 2025 (Release IA-6838): compliance moved to 12 June 2025, to address challenges with the timing of reporting cycles.
• 11 April 2025 (Release IA-6865, 90 FR 15394): joint technical corrections, published and effective that day, fixing errors and cross-references in the amended form and restoring certain July 2023 Section 3 changes left out of the version published in March 2024.
• 11 June 2025 (Release IA-6883): compliance moved to 1 October 2025.
• 17 September 2025 (Release IA-6919): compliance moved to 1 October 2026, to allow a substantive review of the form.
• 20 April 2026: joint proposal (Release IA-6959, 91 FR 22232, 24 April 2026), with comments due by 23 June 2026.
• 31 August 2026: joint final rule (Release IA-6992, 91 FR 56593), published and effective on 3 September 2026, moving compliance to 1 July 2027.

The 2024 package is the one still waiting, and its rebuilt Section 2 also adds currency, country, industry and central counterparty reporting for qualifying hedge funds. The Commissions gave two reasons for the nine-month extension: filers can avoid costs for parts of the 2024 package the proposal would amend or eliminate, and filers keep enough time to comply if the proposal is not adopted in whole or in part.

The SEC fact sheet summarises the April 2026 proposal. It would raise the Form PF filing threshold for all filers from $150 million to $1 billion in private fund assets under management, and raise the large hedge fund adviser threshold from $1.5 billion to $10 billion in hedge fund assets under management. It would also eliminate certain look-through requirements and certain performance volatility reporting, simplify certain large hedge fund counterparty exposure reporting, eliminate certain current reporting for large hedge fund advisers, and eliminate quarterly event reporting for all private equity fund advisers.

The proposal has no legal effect until the Commissions adopt it. The $150 million entry test, the $1.5 billion large hedge fund adviser test, Section 5 current reporting and Section 6 event reporting apply as written in the meantime.

Frequently Asked Questions

Our private fund assets fell below $150 million at fiscal year end. Do we still file the annual update?

The rule tests the condition as of the end of the most recently completed fiscal year, so on my reading an adviser below $150 million at that date is no longer required to file. Instruction 9 then requires a final filing: Item A of Section 1a with the final filing box checked, due no later than the last day on which the next update would have been timely.

We are a large hedge fund adviser with a 31 May fiscal year end. How does the amended form time our first quarterly update after year end?

Under the amended Instruction 9, the next calendar quarter after a 31 May year end closes on 30 June, so the full quarterly update is due within 60 days, by 29 August. The adviser may instead file hedge fund data only by that date and amend within 120 days of fiscal year end, by 28 September, to update its other private funds.

A fund suspends redemptions and lifts the suspension after four business days. Is that an Item I current report?

The suspension limb of Item I requires the suspension to last more than 5 consecutive business days, so a shorter suspension does not meet it. The other limb, inability to pay redemption requests, carries no duration test. Item H can still apply separately if cumulative requests have reached 50% of the most recent net asset value.

Do advisers to venture capital or real estate funds file Section 6 event reports?

Section 6 applies to private equity funds, and the glossary defines a private equity fund to exclude venture capital funds and real estate funds, along with hedge funds, liquidity funds and securitized asset funds. A fund that falls into one of those categories under the glossary definitions sits outside Section 6, whatever the adviser’s size.

An outage at our administrator blocks both a Section 5 report and a quarterly update. Which relief applies to which filing?

Item G’s text lets a current report be filed as soon as practicable when difficulties caused by the operations event prevent timely filing, with the reason explained in Item J. That allowance is written for current reports. For a quarterly or annual update caught in the same outage, the route in the instructions is the temporary hardship exemption, which covers only unanticipated technical difficulties that prevent a timely filing through the Form PF filing system; its request is due no later than one business day after the missed deadline.

Related Articles

• AIFMD II Annex IV Reporting Changes: what the directive changes for the EU supervisory reporting return that AIFMs file.
• AIFMD II Annex IV Leverage Calculation Template: the EU leverage calculation behind the Annex IV exposure figures.
• AIFMD II Liquidity Management Tools: how the harmonised tools, selection duty and calibration standards work under Directive (EU) 2024/927.
• RTRS Reporting: Municipal Trades to the MSRB Within 15 Minutes: a US transaction reporting regime built for public dissemination, with its own clocks and error codes.

Key Takeaways

• Run the Section 2 and Section 3 tier tests month by month: one month-end at or above $1.5 billion in hedge fund assets, or $1 billion in combined money market and liquidity fund assets for an adviser to at least one liquidity fund, in the fiscal quarter immediately preceding the most recently completed fiscal quarter is enough to trigger the tier.
• Plan submissions on the pre-2024 form until the compliance date, and keep the amended-form build alive, because the extension release also covers the case where the April 2026 proposal is not adopted.
• Staff a 72-hour watch for each qualifying hedge fund with the Item D cure-period and disputed-call carve-outs written into the escalation rules.
• Order the private fund identification number through Form ADV before a new fund’s first quarterly Form PF update falls due.
• Version every question-number mapping: Section 2a disappears and Section 2b becomes Section 2 when the amended form applies.
• Track the proposal’s two figures, $1 billion for all filers and $10 billion for large hedge fund advisers; either would change who files and who completes Section 2.

Sources and References

• Code of Federal Regulations, Title 17, Part 275 (4-1-25 edition), including section 275.204(b)-1: govinfo.gov (PDF)
• 17 CFR 279.9, Form PF: govinfo.gov
• CFTC, 17 CFR 4.27 (Additional reporting by commodity pool operators and commodity trading advisors), 4-1-25 edition, including paragraph (d) on dually registered CPOs and CTAs that file Form PF: govinfo.gov (PDF)
• SEC, Form PF reference copy and General Instructions, SEC 2048 (4-25): sec.gov (PDF)
• SEC and CFTC, Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers, Release No. IA-6546, 89 FR 17984 (12 March 2024): Federal Register 2024-03473 (PDF)
• SEC and CFTC, Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (technical corrections), Release No. IA-6865, 90 FR 15394 (11 April 2025): Federal Register 2025-05267 (PDF)
• SEC and CFTC, Form PF; Further Extension of Compliance Date, Release No. IA-6992, 91 FR 56593 (3 September 2026): Federal Register 2026-18104 (PDF)
• SEC and CFTC, Form PF; Reporting Requirements for All Filers, Release No. IA-6959 (20 April 2026), proposal page: sec.gov
• SEC, Fact Sheet: Proposed Amendments to Form PF (April 2026): sec.gov (PDF)
• SEC, Form PF; Event Reporting for Large Hedge Fund Advisers and Private Equity Fund Advisers; Requirements for Large Private Equity Fund Adviser Reporting, Release No. IA-6297 (3 May 2023): sec.gov
• SEC Division of Investment Management, Form PF Frequently Asked Questions: sec.gov
• FINRA, PFRD User Support (Classic IARD/PFRD filing requirement before 1 July 2027; Form PF schema documentation and system release notes): iard.com
• FINRA, Future PFRD Releases (amended Form PF XML schema milestones: final schema published 2 March 2026, QA test environment February 2026 to June 2027, production deployment 1 July 2027): iard.com

The Form PF file to hold before 1 July 2027

The working file for Form PF reporting has five parts: a threshold workpaper reconciled to Form ADV; a fund-by-fund section map built on the glossary tests; a Section 5 trigger log; the filing receipts; and a gap analysis of the amended form against the pre-2024 version, held open until the Commissions decide on the April 2026 proposal. The 2024 amendments have a compliance date of 1 July 2027, but the applicable filing build must be determined from the filing obligation and transition rules: FINRA currently directs filings due before that date to Classic IARD/PFRD, while the 2024 amendments also contain specific transition timing for quarterly filers.

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