Frequently Asked Questions
Form PF

Form PF is a confidential regulatory reporting form adopted after the Dodd-Frank Wall Street Reform and Consumer Protection Act. The form is designed to collect information from certain private fund advisers so regulators can monitor systemic risk and support regulatory oversight of private fund advisers. Form PF can apply to different types of private funds, including hedge funds, liquidity funds, and private equity funds, depending on the investment adviser’s status, private fund assets under management, fund types, and applicable Form PF instructions.

Under the current Form PF instructions, an investment adviser generally must complete and file Form PF if it is registered or required to register with the SEC as an investment adviser, or is registered or required to register with the CFTC as a commodity pool operator or commodity trading advisor and is also registered or required to register with the SEC as an investment adviser; manages one or more private funds; and, together with its related persons, had at least $150 million in private fund assets under management as of the last day of its most recently completed fiscal year. For purposes of this reporting threshold, Form PF states that an investment adviser is not required to include the regulatory assets under management of a related person that is separately operated. Filing frequency and the sections required depend on the investment adviser’s private fund assets under management, the types of private funds advised, and the applicable Form PF instructions.

Many private fund advisers that meet the Form PF filing threshold but do not meet a large adviser threshold file Form PF annually and complete only the sections applicable to their advisory business and private funds. Large private fund advisers must provide additional information and, in some cases, file more frequently. Under the current Form PF framework, large-adviser status depends on the type of private fund advised and the applicable measurement instructions. Form PF currently includes separate large-adviser categories for large hedge fund advisers, large liquidity fund advisers, and large private equity fund advisers. The principal current thresholds include $1.5 billion in hedge fund assets under management for large hedge fund adviser reporting, $1 billion in combined liquidity fund and money market fund assets for large liquidity fund adviser reporting, and $2 billion in private equity fund assets under management for large private equity fund adviser reporting. Advisers should apply the definitions and aggregation instructions in Form PF before determining their filing category, because master-feeder structures, parallel fund structures, trading vehicles, dependent parallel managed accounts, and related-person relationships can affect the analysis.

Form PF filing deadlines depend on the adviser’s filing category. Annual filers generally file an annual update within 120 calendar days after the end of the adviser’s fiscal year. Large hedge fund advisers generally file quarterly updates for hedge funds within 60 calendar days after the end of each calendar quarter. Large liquidity fund advisers generally file quarterly updates for liquidity funds within 15 calendar days after the end of each calendar quarter. Investment advisers that are both large hedge fund advisers and large liquidity fund advisers must follow the applicable deadline for each fund type. Form PF also includes event-based reporting. Large hedge fund advisers must file a Section 5 current report upon certain current reporting events for qualifying hedge funds as soon as practicable, but no later than 72 hours. Advisers to private equity funds must consider Section 6 private equity event reporting for specified private equity reporting events. Because filing deadlines and required sections depend on the adviser’s specific facts, advisers should review the current Form PF instructions before filing.

The SEC and CFTC adopted amendments to Form PF in February 2024. The agencies later extended the compliance date for those amendments to October 1, 2026. Separately, on April 20, 2026, the SEC and CFTC proposed additional amendments to Form PF that, if adopted, would raise the general Form PF filing threshold from $150 million in private fund assets under management to $1 billion, raise the large hedge fund adviser threshold from $1.5 billion in hedge fund assets under management to $10 billion, and eliminate or streamline certain reporting obligations. The 2026 proposal has not itself been adopted as final based on the sources reviewed for this draft. Investment advisers should distinguish current requirements from proposed amendments before deciding whether a Form PF filing obligation applies.

Form PF is filed electronically through the Private Fund Reporting Depository, or PFRD, which is a subsystem of the Investment Adviser Registration Depository, or IARD website. A paper version of Form PF is only a reference copy and cannot be submitted to satisfy a filing obligation. Filings may be completed through the PFRD online form or, where applicable, through XML submission.

FINRA filing fees currently apply to Form PF annual reports and quarterly reports filed through PFRD. As of August 2026, SEC-registered advisers filing Form PF are charged $150 for each annual report and $150 for each quarterly report. No fee is charged for filing an electronic amendment to Form PF, a final Form PF filing, or a transition-to-annual-reporting filing.

Additional information is available from the SEC’s Form PF instructions, the SEC’s Form PF Frequently Asked Questions, and the SEC’s PFRD information page. Investment advisers should also monitor SEC and CFTC rulemaking because the Form PF framework has been amended several times and remains subject to pending proposed amendments.

Generally, no. Under the current Form PF instructions, an adviser generally must file Form PF only if it is registered or required to register with the SEC as an investment adviser, or meets the applicable SEC and CFTC dual-registration condition, manages one or more private funds, and the adviser and its related persons collectively had at least $150 million in private fund assets under management as of the last day of the adviser’s most recently completed fiscal year. A proposed 2026 amendment would increase this threshold to $1 billion, but that proposal should not be treated as current law unless and until adopted.

Form PF contains detailed instructions for determining when private funds, master-feeder arrangements, parallel fund structures, dependent parallel managed accounts, related persons, and trading vehicles must be aggregated or reported separately. These determinations can affect whether an adviser must file Form PF, whether it is treated as a large private fund adviser, and which sections of Form PF must be completed. Advisers should review the Form PF instructions and glossary before determining how to report complex fund structures.

In some circumstances, Form PF permits or contemplates the use of estimates, but the adviser should follow the instructions for the specific question and use explanatory notes where appropriate. For example, SEC staff FAQs address circumstances where audited financial statement information is not yet available and indicate that the adviser should use estimated values for the fiscal year being reported and explain that the information is an estimate in the applicable explanatory note.