The IAA Submits Comment Letter to the SEC and CFTC on Proposed Form PF Amendments
June 23, 2026
Contact:
IAA Vice President, Communications & Marketing, Janay Rickwalder, CAE
Washington, DC (June 23, 2026) – Today, the Investment Adviser Association submitted comments on proposed amendments to Form PF, the confidential reporting form that private fund advisers are required to file with the Securities and Exchange Commission (SEC). We commend the SEC and the Commodity Futures Trading Commission (CFTC) for their thoughtful proposal, which we strongly support in large part. We recommend several additional changes to improve the form.
Form PF was adopted under the Dodd-Frank Act to provide the SEC and Financial Stability Oversight Council (FSOC) with information about private funds to help monitor systemic risk. The proposal represents the third set of amendments to Form PF since 2022. Among other things, it would update reporting thresholds established in 2011 to reflect the significant growth of the private fund industry and amend or eliminate certain reporting items.
The IAA strongly supports the proposed threshold changes, which would provide meaningful relief to small private fund advisers by eliminating or substantially reducing their reporting obligations. Following years of IAA advocacy on behalf of smaller advisers, the SEC recently proposed to update its definition of small adviser to require it to conduct a more realistic impact analysis in its rulemakings. We commend the SEC for taking concrete steps to ensure that regulatory requirements are appropriately tailored for smaller advisers, and we view the Form PF proposal as a significant step in that direction.
The IAA also commends the SEC and CFTC for reducing operational complexity and compliance burdens across the form by eliminating or simplifying a number of reporting items that are not necessary for systemic risk assessment. In our comment letter, we recommend several additional changes that would further streamline the form and reduce operational and compliance burdens while preserving the utility of Form PF for systemic risk assessment.
Given the complexity of Form PF, the IAA believes it is critical that the SEC and CFTC provide sufficient time for the development and testing of updated technical specifications, a process managed by FINRA. Advisers and their service providers will then need adequate time to update systems and processes to collect, validate, and analyze data in accordance with the revised requirements. The IAA also urges the agencies to continue maintaining robust safeguards to protect the confidentiality of Form PF.
The IAA looks forward to continuing to work with the SEC and CFTC to further improve Form PF and eliminate unnecessary reporting burdens while preserving the form’s effectiveness for systemic risk monitoring.
