Glossary · Legal, regulatory & tax
Form PF
Also called: Form PF filing
Form PF is the confidential report on private funds that an investment adviser registered with the Securities and Exchange Commission (SEC) files once its private fund assets reach $150 million, so regulators can monitor systemic risk.
Form PF gives regulators data the public never sees: fund sizes, leverage, liquidity, counterparties, investor concentration and, for large managers, much more detail. Smaller advisers report a short set of data once a year; large hedge fund and private equity advisers report more, and some events must be reported within days. The form's 2024 overhaul has repeatedly been postponed.
Jurisdiction and status
Form PF is required by Rule 204(b)-1 under the Investment Advisers Act of 1940. An adviser must file if it is registered with the SEC or required to register, advises one or more private funds, and, together with its related persons, managed $150 million or more in private fund assets at the end of its most recently completed fiscal year (General Instruction 1). Filings go through the Form PF filing system operated by the Financial Industry Regulatory Authority (FINRA). The form is joint with the Commodity Futures Trading Commission (CFTC) for advisers that are also registered commodity pool operators or commodity trading advisors.
| Change | Status on 2 October 2026 | Federal Register (FR) citation |
|---|---|---|
| 2023 SEC amendments (Release IA-6297): event reporting for large hedge fund advisers and private equity advisers | In force. Sections 5 and 6 effective 11 December 2023; remainder effective 11 June 2024 | 88 FR 38146 |
| 2024 joint SEC/CFTC amendments (adopted 8 February 2024) | Adopted, not yet required. Compliance date moved 12 March 2025 → 12 June 2025 → 1 October 2025 → 1 October 2026 → 1 July 2027 | 91 FR 56593 (3 September 2026) |
| April 2026 joint proposal: raise the filing threshold from $150m to $1bn and delete section 6, among other changes | Proposed, not adopted as of 2 October 2026 (published 24 April 2026; comments closed 23 June 2026) | 91 FR 22232 (Tables 1a–1b), 22257 |
Who reports what
| Filer | Threshold | Main obligations |
|---|---|---|
| Private fund adviser (all filers) | $150 million or more in private fund assets | Section 1: adviser and fund-level data; filed annually |
| Large hedge fund adviser | At least $1.5 billion in hedge fund assets | Section 2 detail, filed quarterly; Section 5 current reports within 72 hours of specified stress events |
| Adviser to private equity funds | No separate threshold: every Form PF filer that advises a private equity fund | Section 6 event reports within 60 calendar days after the end of each fiscal quarter: adviser-led secondary transactions, removal of a general partner, and certain fund or investment-period terminations |
| Large private equity fund adviser | At least $2 billion in private equity fund assets | Section 4 detail, filed annually, including any general partner clawback and limited partner clawbacks above 10% of aggregate capital commitments |
| Large liquidity fund adviser | At least $1 billion in combined money market and liquidity fund assets | Section 3 detail, filed quarterly within 15 calendar days of quarter-end |
Under General Instruction 9, annual updates are due within 120 calendar days of fiscal year-end, quarterly updates by large hedge fund advisers within 60 calendar days of quarter-end, and quarterly updates by large liquidity fund advisers within 15 calendar days. Thresholds count the private fund assets of the adviser and its related persons together, except related persons that are separately operated, and related persons may report on a single Form PF (General Instructions 1-3).
Why private equity investors should know it
The 2023 amendments made several events in a private equity fund's life reportable to the SEC: a GP-led secondary run by the adviser, the removal of a general partner (see removal for cause and no-fault divorce), an LP vote to end the investment period or terminate the fund, and, in the annual Section 4 filing of large private equity advisers, any general partner clawback and limited partner clawbacks above 10% of the fund's aggregate capital commitments. LPs do not see the reports, but advisers' compliance calendars now track these events.
Confidentiality and data use
Form PF filings are not public. They cannot be used to profile individual managers; the data reach the public only in aggregated statistics and staff reports. Public data on private fund advisers come from Form ADV and Form D.
The legal basis is Advisers Act section 204(b)(8): the SEC may not be compelled to disclose reports filed under section 204(b), or information in them, except that the SEC may share them with Congress under an agreement of confidentiality, with other federal departments or agencies and self-regulatory organisations for purposes within their jurisdiction, and in compliance with an order of a US court in an action brought by the United States or the SEC.
Not to be confused with the vacated 2023 private fund rules
Form PF is separate from the SEC's 2023 Private Fund Adviser Rules (quarterly statements, mandatory audits, the adviser-led secondaries rule, restricted activities and preferential-treatment rules). The Fifth Circuit vacated those rules on 5 June 2024 and the SEC removed them from the CFR on 19 November 2024. The 2023 Form PF amendments were adopted separately and remain in force.
Not the same as
- Form ADV: Form ADV is public and filed by all registered and exempt reporting advisers; Form PF is confidential and filed only by registered private fund advisers that meet its $150 million threshold.
Common mistakes
- Stating that the 2024 Form PF amendments apply now. Their compliance date is 1 July 2027 and a narrowing proposal is pending.
- Treating the 2023 Form PF event-reporting amendments as part of the vacated Private Fund Adviser Rules. They are separate and in force.
- Assuming exempt reporting advisers file Form PF. The obligation applies to SEC-registered advisers.
- Looking for individual Form PF filings as a data source. They are confidential.
Edge cases
- Thresholds are measured on private fund assets of the adviser and its related persons, aggregated by fund type, so a manager can be a large adviser for one strategy and a smaller filer for another.
Questions
When do the 2024 Form PF amendments take effect?
The compliance date is 1 July 2027, after four extensions. An April 2026 SEC/CFTC proposal, not adopted as of 2 October 2026, would raise the filing threshold from $150m to $1bn and delete section 6, so the final shape may change again.
Is Form PF public?
No. Individual filings are confidential; regulators publish only aggregate statistics.
Sources
- 17 CFR 275.204(b)-1 - Reporting by investment advisers to private funds (Form PF filing obligation). U.S. Securities and Exchange Commission (CFR text via eCFR; LII mirror), eCFR current as of 2026-09-29; last amended 2025-03-12. Status: in force (2024 Form PF amendments not yet in compliance) (checked 2026-10-01). 17 CFR 275.204(b)-1(a)-(b) — supports: Filing obligation for advisers registered or required to register with at least $150 million in private fund assets at fiscal year-end; filed on the Form PF filing system on IARD
- Form PF; Event Reporting for Large Hedge Fund Advisers and Private Equity Fund Advisers; Requirements for Large Private Equity Fund Adviser Reporting (final rule), Release IA-6297, 88 FR 38146. U.S. Securities and Exchange Commission (Federal Register via govinfo), Adopted 2023-05-03; published 2023-06-12; sections 5 and 6 effective 2023-12-11; remainder effective 2024-06-11. Status: in force (checked 2026-10-01). 88 FR 38146 (Release IA-6297): DATES; section II.C ("Quarterly Reporting ... for All Private Equity Fund Advisers") — supports: 2023 amendments: Sections 5 and 6 effective 2023-12-11, remainder 2024-06-11; Section 5 current reports; Section 6 event reporting for all private equity fund advisers that file Form PF
- Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (joint final rule), 89 FR 17984. U.S. Securities and Exchange Commission and Commodity Futures Trading Commission (Federal Register via govinfo), Adopted 2024-02-08; published 2024-03-12; original effective/compliance 2025-03-12. Status: adopted; compliance date moved to 2027-07-01 (checked 2026-10-01). 89 FR 17984 — supports: 2024 joint SEC/CFTC amendments adopted 8 February 2024
- Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers; Further Extension of Compliance Date (joint final rule), 91 FR 56593. U.S. Securities and Exchange Commission and Commodity Futures Trading Commission (Federal Register via govinfo), Published and effective 2026-09-03. Status: in force (checked 2026-10-01). 91 FR 56593 (2026-09-03) — supports: Compliance date extended to 1 July 2027
- Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (rulemaking page, File No. S7-22-22). U.S. Securities and Exchange Commission, Latest action IA-6992 (2026-08-31). Status: adopted; compliance date extended to 2027-07-01 (checked 2026-10-01). Rulemaking page, File S7-22-22 — supports: Extension history IA-6838, IA-6883, IA-6919, IA-6992
- Form PF; Reporting Requirements for All Filers (joint proposed rules), 91 FR 22232. U.S. Securities and Exchange Commission and Commodity Futures Trading Commission (Federal Register via govinfo), Proposed 2026-04-20; published 2026-04-24; comments due 2026-06-23. Status: proposed (checked 2026-10-01). 91 FR 22232 (2026-04-24): SUMMARY; DATES — supports: April 2026 proposal to raise the filing threshold to $1bn and delete section 6 (Tables 1a-1b; 91 FR 22257); comments due 2026-06-23; still described as proposed in 91 FR 56593 (2026-09-03)
- Announcement Regarding the Private Fund Advisers Rules. U.S. Securities and Exchange Commission, 2024-10-31. Status: current (checked 2026-10-01). Announcement of 2024-10-31 — supports: Scope of vacated Private Fund Adviser Rules
- National Association of Private Fund Managers v. SEC, No. 23-60471 (5th Cir. June 5, 2024). U.S. Court of Appeals for the Fifth Circuit (via govinfo, USCOURTS collection), Decided 2024-06-05. Status: final (checked 2026-10-01). No. 23-60471 (5th Cir. 2024-06-05) — supports: Vacatur of the Private Fund Adviser Rules
- Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews (final rule; technical amendments), 89 FR 91252. U.S. Securities and Exchange Commission (Federal Register via govinfo), Published and effective 2024-11-19. Status: in force (checked 2026-10-01). 89 FR 91252 (2024-11-19) — supports: Removal of vacated rule text from the CFR
- Form PF (reference copy): General Instructions and Glossary. U.S. Securities and Exchange Commission, Reference copy posted at sec.gov/files/formpf.pdf, OMB No. 3235-0679; includes Sections 5 and 6 added by the 2023 amendments. Status: current (checked 2026-10-01). General Instructions 1-3, 9; Section 4 Question 84; Section 5 (72-hour current report); Section 6 — supports: Filing conditions, related-person aggregation and separately operated exclusion, large-adviser thresholds, filing deadlines, Section 6 for all advisers to private equity funds within 60 days after fiscal quarter-end, clawback reporting threshold
- 15 U.S.C. 80b-4 - Reports by investment advisers (Advisers Act s.204), incl. s.204(b) records and reports of private funds. U.S. Congress (US Code via LII), Current US Code text as published by LII (accessed 2026-10-01). Status: in force (checked 2026-10-01). Sec. 204(b)(8)(A)-(B) — supports: SEC may not be compelled to disclose Form PF reports; exceptions for Congress, other federal agencies and SROs, and court orders in actions by the US or the SEC
- 17 CFR 275.204-4 - Reporting by exempt reporting advisers. U.S. Securities and Exchange Commission (CFR text via eCFR; LII mirror), eCFR current as of 2026-09-29; no substantive amendment since eCFR baseline. Status: in force (checked 2026-10-01). 17 CFR 275.204-4(d) — supports: FINRA is the operator of the IARD