Form PF: Who Files, What to Report and When It Is Due

Form PF is a confidential report that SEC-registered investment advisers file about the private funds they manage, so that the SEC, the CFTC and the Financial Stability Oversight Council can monitor systemic risk. An adviser must file if it and its related persons manage at least $150 million in private fund assets; how often it files and how much it reports depend on whether it is a smaller adviser or a "large" hedge fund, liquidity fund or private equity adviser. As of late 2026, a broad set of 2024 amendments is still waiting to take effect and a separate proposal would cut the filer population significantly.

Who has to file Form PF#

Three conditions must all be true:

1. You are registered with the SEC as an investment adviser. Exempt reporting advisers (venture capital advisers and advisers relying on the private fund adviser exemption) and state-registered advisers do not file Form PF. Dual registrants that are also CFTC-registered commodity pool operators or commodity trading advisors file through the same form.
2. You advise at least one private fund. For these purposes a private fund is an issuer that would be an investment company but for section 3(c)(1) or 3(c)(7) of the Investment Company Act.
3. You and your related persons, together, had at least $150 million in private fund assets under management as of the last day of your most recently completed fiscal year.

The asset figure is regulatory assets under management, the same gross measure used on Form ADV. For private funds that means gross assets, with no deduction for fund-level borrowing, plus uncalled capital commitments. A first-time manager with a $160 million fund that has called only 20% of commitments is therefore already over the threshold. If you are newer to the registration framework, our guide to the registered investment adviser regime explains how these AUM calculations are built.

Filer categories and deadlines#

Once you are in, your category determines what you complete and when. The thresholds below are those in the current Form PF instructions.

Two event-driven reports sit on top of the periodic filings:

• Section 5 current reports. Large hedge fund advisers report certain stress events at qualifying hedge funds (such as extraordinary investment losses, significant margin or counterparty events, or the inability to meet redemptions) as soon as practicable and no later than 72 hours after the event.
• Section 6 private equity event reports. Every private equity fund adviser that files Form PF, not only large ones, must report within 60 days after the end of a fiscal quarter in which a reporting event occurred: completion of an adviser-led secondary transaction, investor removal of the general partner, or investor election to end the investment period or terminate the fund. If nothing happened in a quarter, no Section 6 filing is due.

These two sections came from amendments the SEC adopted in May 2023, which took effect on December 11, 2023. The same release expanded Section 4 for large private equity advisers (for example, adding general partner and limited partner clawback reporting on an annual basis), effective June 11, 2024.

What the form actually asks#

Most private markets advisers live in Sections 1 and 4, so it helps to know the content before the data request lands.

Section 1: every filer#

Section 1a identifies the adviser and its related persons and reports aggregate assets by fund type. Section 1b is completed for each private fund and covers gross and net asset value, borrowings and their sources, fair value hierarchy breakdowns, investor concentration and investor type, and fund performance. Section 1c adds strategy, counterparty and trading information for hedge funds.

Section 4: large private equity advisers#

Section 4 asks, fund by fund, about leverage at both the fund and portfolio company level, guarantees and bridge financing, investments in financial industry portfolio companies, geographic and industry exposure, controlled portfolio companies, and the events now captured annually, such as clawbacks.

Practical data sources#

Almost every answer traces back to records you already keep: the fund general ledger, the schedule of investments, commitment and capital account data, the valuation file, and the subscription documents that record investor type. The quality problem is rarely missing data. It is data that doesn't reconcile, such as a NAV on Form PF that differs from the audited financial statements or a regulatory AUM that differs from Form ADV.

A worked example#

Assume a private equity adviser with a December 31 fiscal year-end manages, together with its related persons, the following at year-end:

The adviser is above $150 million, so it files. It is below the $2 billion private equity threshold, so it is not a large private equity adviser and completes only Section 1. Its annual filing is due 120 days after December 31, which is April 30 in a non-leap year.

Now assume the adviser runs a continuation-vehicle process for one Fund I asset that closes in May. That is an adviser-led secondary, so a Section 6 report is due within 60 days after the June 30 quarter-end: by August 29. If Fund II's assets later grow so that private equity AUM crosses $2 billion at a fiscal year-end, the next annual filing would add Section 4.

The 2024 amendments and the 2026 proposal#

In February 2024 the SEC and CFTC jointly adopted extensive amendments to Form PF. They would require more granular reporting, including more detail on each fund in master-feeder and parallel structures, expanded look-through to underlying fund investments, and substantially more hedge fund data. The compliance date has been pushed back several times. On August 31, 2026, the two agencies issued a joint final rule moving it from October 1, 2026 to July 1, 2027. Until then, advisers keep filing on the existing form.

The agencies said the delay gives them time to consider comments on a proposal they issued on April 20, 2026. According to the SEC's fact sheet, that proposal would:

• Raise the Form PF filing threshold for all filers from $150 million to $1 billion in private fund AUM.
• Raise the large hedge fund adviser threshold from $1.5 billion to $10 billion in hedge fund AUM.
• Eliminate quarterly event reporting (Section 6) for all private equity fund advisers.
• Eliminate certain current reporting for large hedge fund advisers, certain look-through requirements and certain performance volatility items, and simplify counterparty exposure reporting.

The comment period has closed but, as of late 2026, the proposal has not been adopted. Until a final rule says otherwise, the existing thresholds, Section 6 reporting and other current requirements remain in force. Managers between $150 million and $1 billion should keep filing while watching for a final rule. For context on the broader shift in private fund regulation, see our article on the SEC's Private Fund Adviser Rules.

A repeatable filing process#

Form PF is most painful when it is treated as a once-a-year scramble. A simple, repeatable process looks like this:

1. Confirm status at fiscal year-end. Recalculate regulatory AUM by fund type, including related persons and uncalled commitments, and decide whether you are a smaller or large filer for the coming period.
2. Lock the source data. Use final year-end NAVs, the investment schedule and investor records that tie to the audit and to Form ADV.
3. Map data to questions. Maintain a mapping file from each Form PF item to its source report so the work is repeatable and reviewable.
4. Set a quarterly event check. At each quarter-end, confirm with deal and legal teams whether any Section 6 event occurred, and calendar the 60-day deadline.
5. Review and file through PFRD. Filings are made electronically through the Private Fund Reporting Depository on FINRA's IARD system. Keep the final filing and supporting workpapers in your books and records.
6. Track rule changes. Diary the July 1, 2027 compliance date and any action on the 2026 proposal, since either could change what you file next year.

A broader view of how this fits into your compliance calendar is in our private equity compliance guide, and much of the data assembly is often shared with the fund administrator.

How Privatis helps#

Privatis keeps the inputs Form PF depends on in one system: a double-entry fund general ledger with period close, NAV and portfolio valuations, commitment and capital account data for every investor, and an audit trail of every change. The compliance filings calendar tracks annual and quarterly deadlines, including Section 6 event windows, so the team sees what is due before it is late, and the numbers reported reconcile to the same records used for investor reporting and the audit.

Thresholds, deadlines and the status of the 2024 amendments and 2026 proposal can change, so confirm your filing obligations with counsel.