Form PF; Reporting Requirements for All Filers
Published on:
June 23, 2026
Submitted to:
SEC and CFTC
Submitted by:
SIFMA AMG
File Number:
S7-2026-13
Committee:
Summary
SIFMA AMG 1 provided comments to the U.S. Securities and Exchange Commission (SEC) and U.S. Commodity Futures Trading Commission (CFTC) in response to the joint proposed rule amendments to reporting on Form PF.
Excerpt
The 2026 proposed amendments (the “2026 Proposal”) would:
- raise the Form PF filing threshold for all filers and raise the reporting threshold for large hedge fund advisers.
- streamline or eliminate certain Form PF requirements.
- make a variety of technical corrections and revisions.
I. Executive Summary
SIFMA AMG supports the proposal’s objectives and believes the proposal can be improved in several respects:
- Periodically re-calibrating Form PF reporting is good public policy to ensure the form serves the original systemic risk purposes, such as refining the funds in scope and information required
- The definition of “hedge fund” should be narrowed
- Trading vehicle reporting should be eliminated
- Current reporting should be reconsidered and, if retained, should be extended beyond the current 72 hour notice period
- There are opportunities to further clarify current Form PF questions or instructions
- An implementation period of at least 18 months is warranted and a compliance date should be set just after annual and quarterly reports are due.
- SIFMA’s Asset Management Group (SIFMA AMG) brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms that manage more than 50% of global AUM. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds. For more information, visit http://www.sifma.org/amg.