The White House is reviewing a joint proposal from the SEC and CFTC that would fundamentally reshape how private fund advisers report their swaps and security-based swaps activity. The changes center on Form PF, the confidential reporting form that private fund advisers have filed since the Dodd-Frank era, and the revisions would raise reporting thresholds high enough to let nearly half of current filers off the hook entirely.
What the proposal actually changes
The SEC and CFTC are expected to jointly propose amendments to Form PF around April 20, 2026. The headline number: the reporting threshold for private fund advisers would jump from $150 million to $1 billion in assets under management.
For large hedge fund advisers specifically, the exposure reporting threshold would climb from $1.5 billion to $10 billion in AUM. Only the biggest players in the hedge fund world would need to submit the most detailed layer of reporting.
Despite the dramatically higher thresholds, over 90% of private fund gross assets would still fall under the reporting umbrella. Nearly half of current Form PF filers would be exempted under the new thresholds.
The broader regulatory context
In December 2025, the CFTC finalized revisions to swap dealer business conduct rules around documentation requirements. In April 2025, the SEC extended a provision allowing market participants to continue using CFTC-style reporting for certain security-based swaps through November 5, 2029.
The White House review also encompasses proposals related to prediction markets, suggesting a broader appetite for recalibrating financial regulation across multiple asset classes simultaneously.
What this means for investors
For smaller private fund advisers managing between $150 million and $1 billion, the elimination of Form PF filing requirements would free up resources currently dedicated to regulatory reporting. The harmonization effort between the SEC and CFTC carries implications for digital asset-linked derivatives, where the same product might face different reporting requirements depending on which agency claims jurisdiction.
Raising thresholds means less granular data on mid-sized funds. Regulators are betting that the data they lose from exempted filers isn’t material to their oversight mission, while still maintaining coverage of over 90% of private fund gross assets.
Firms operating in both traditional and digital asset derivatives markets should be tracking this proposal closely. The comment period following the formal proposal will be the window to shape final rules, and the thresholds that emerge from that process will define compliance obligations for years to come.
