An investment adviser registered with the SEC that runs two hedge funds holding $160 million between them owes the SEC one confidential report a year, due 120 days after its fiscal year ends. Once the same firm passes $1.5 billion in hedge fund assets, with at least one fund holding $500 million or more of net assets, the report turns quarterly and falls due 60 days after each quarter. The firm must also tell the SEC within 72 hours when one of those large funds loses 20% or more over ten business days. Every one of those obligations sits in the same document, Form PF.
Form PF is the confidential report on private funds that an SEC-registered investment adviser files once it and its related persons manage at least $150 million in private fund assets. The SEC and the Commodity Futures Trading Commission (CFTC) adopted it on October 31, 2011 to carry out sections 404 and 406 of the Dodd-Frank Act. The data goes to the Financial Stability Oversight Council (FSOC) to monitor systemic risk, and the SEC also uses it to plan examinations and rules.
The largest advisers, those with at least $5 billion in hedge fund, liquidity fund or private equity assets, had to comply from June 15, 2012. All others followed on December 15, 2012, and most of them filed a first report on data as of December 31, 2012.
Who has to file Form PF
An adviser files Form PF when three conditions hold at the same time:
- It is registered, or required to register, with the SEC as an investment adviser. Advisers that are also registered with the CFTC as a commodity pool operator or commodity trading adviser file the same form, and its first two sections are joint SEC and CFTC sections.
- It advises at least one private fund, meaning a fund that stays outside the Investment Company Act through the exclusions in its section 3(c)(1) or 3(c)(7), which most hedge funds and private equity funds use. Our guide to what a hedge fund is covers how those funds are structured.
- It and its related persons together had at least $150 million in private fund assets under management on the last day of its most recent fiscal year.
Exempt reporting advisers file no Form PF. That group covers advisers that manage only venture capital funds and advisers that manage only private funds with less than $150 million of assets in the United States. State-registered advisers do not file it either, and neither do SEC-registered advisers below $150 million in private fund assets. All of them report basic data on their private funds in Form ADV instead.
An adviser based outside the United States can leave out any private fund that, during its last fiscal year, was not a US person, was not offered in the United States and had no US beneficial owner.
In the fourth quarter of 2025, 4,153 advisers reported 58,891 private funds on Form PF, with $29.6 trillion of gross assets and $19.0 trillion of net assets. Private equity was the largest category by number, with 27,682 funds. Hedge funds were the largest by gross assets, at $14.4 trillion.
Form PF thresholds and deadlines by type of adviser
Every filer completes Section 1. The size of the adviser then decides which other sections apply and how often the form comes due. Each threshold adds up the assets of the adviser and its related persons, leaving out related persons that are operated separately. All deadlines are in calendar days.
| Filer | Threshold | Sections completed | Frequency | Deadline |
|---|---|---|---|---|
| Every filer | $150 million in private fund assets at fiscal year end | 1a and 1b, plus 1c for each hedge fund | Annual | 120 days after fiscal year end |
| Large hedge fund adviser | $1.5 billion in hedge fund assets at the end of any month of the previous quarter | Section 1, plus Section 2 | Quarterly | 60 days after quarter end |
| Large liquidity fund adviser | $1 billion in liquidity fund and money market fund assets at the end of any month of the previous quarter | Section 1, plus Section 3 for each liquidity fund | Quarterly | 15 days after quarter end |
| Large private equity fund adviser | $2 billion in private equity fund assets at fiscal year end | Section 1, plus Section 4 for each private equity fund | Annual | 120 days after fiscal year end |
| Large hedge fund adviser, after a trigger event | Event at a qualifying hedge fund | Section 5 | Each time an event occurs | 72 hours |
| Any filer that advises a private equity fund | Event during the quarter | Section 6 | Only for quarters with an event | 60 days after quarter end |
A qualifying hedge fund is a hedge fund with a net asset value of at least $500 million. The per-fund part of Section 2 is completed one qualifying hedge fund at a time, so an adviser with six of them fills it in six times every quarter. At the end of 2025, 637 advisers reported 2,178 qualifying hedge funds. Those funds held $12.6 trillion of the $14.4 trillion of hedge fund gross assets on Form PF, or 87%.
Under the version of the form in use today, quarterly deadlines follow each adviser's fiscal quarters, and the fourth-quarter filing updates every item on the form, including the funds outside the large category. The 2024 amendments move all quarterly filers to calendar quarters when they take effect.
What each section of Form PF asks for
- Section 1a, the adviser
- The adviser and the related persons filing with it, and its regulatory assets under management and net assets split among hedge funds, liquidity funds, private equity funds and other private funds.
- Section 1b, each private fund
- Gross and net asset value, borrowings by type of creditor, assets and liabilities by level of the fair value hierarchy, the share of the fund owned by its largest investors and by each type of investor, and gross and net performance.
- Section 1c, each hedge fund
- Strategies as a share of net assets, the share managed with high-frequency trading strategies, the five counterparties with the largest net credit exposure in each direction, and how the fund's trades are cleared.
- Section 2, large hedge fund advisers
- A first part aggregates long and short exposures, monthly turnover and geographic breakdown across all of the adviser's hedge funds. A second part covers each qualifying hedge fund: exposures by asset class, every position worth 5% or more of net assets, value at risk, the effect of set moves in equity prices, interest rates, credit spreads and currencies, how fast the portfolio could be sold, how long its financing is committed, its creditors and collateral, and how quickly investors can withdraw.
- Section 3, each liquidity fund
- Whether the fund keeps a stable share price, its monthly net asset value per share, maturity and 7-day yield, investor concentration, redemption terms and a monthly security-by-security list of holdings, with many items matched to what money market funds report on Form N-MFP.
- Section 4, each private equity fund
- Debt-to-equity ratios and borrowings of the companies the fund controls, bridge financing, defaults, and investments broken down by industry and geography. Since June 11, 2024, it also covers clawbacks by general or limited partners, the fund's strategy and its use of leverage.
- Section 5, current reports
- Filed within 72 hours of specified events at a qualifying hedge fund.
- Section 6, private equity event reports
- Filed after an adviser-led secondary transaction, a removal of the general partner or an investor vote to end the fund or its investment period.
- Section 7, temporary hardship exemption
- A paper request, made no later than one business day after a filing was due, that gives an adviser facing unexpected technical problems seven more business days to file.
Advisers may answer with their own internal methodologies and their service providers' conventions, provided the figures match what they report internally and to investors and the methods are applied the same way every period. The SEC staff's Form PF FAQ settles many of the calculation questions, such as how to count short positions in gross asset value.
The 72-hour current report for large hedge fund advisers
Section 5 has applied since December 11, 2023. A large hedge fund adviser must file it "as soon as practicable, but no later than 72 hours" after any of the following events at a qualifying hedge fund. The clock starts at the event, or at the moment the adviser reasonably believes it occurred.
- Extraordinary investment loss. A holding period return of minus 20% or worse over ten business days.
- Margin increase. Margin and collateral posted rise, over a rolling ten business days, by at least 20% of the fund's average daily aggregate calculated value, the form's measure of total positions.
- Margin default. The fund is in default on a margin call it cannot cover, or the adviser determines it will be unable to meet one.
- Counterparty default. A counterparty misses a margin call or another payment worth more than 5% of the fund's aggregate calculated value.
- Prime broker exit. A prime broker ends or materially restricts its relationship with the fund.
- Operations event. A significant disruption of the fund's trading, valuation, reporting, risk management or legal compliance, whether it starts at the fund, the adviser or a service provider.
- Redemption requests. Net withdrawal requests reach 50% of the most recent net asset value.
- Frozen redemptions. The fund cannot pay redemption requests, or suspends redemptions for more than five consecutive business days.
About 258 current reports are filed a year, on early 2025 data, at an estimated $8,873 of staff time each.
The quarterly Section 2 filing also asks what share of each qualifying hedge fund's net assets could be gated or suspended. Our guide to side pockets, gates and suspensions covers how those tools work in practice.
Quarterly event reports for private equity advisers
Section 6 took effect on the same day as Section 5. It applies to Form PF filers that advise private equity funds, including those below the $2 billion large adviser threshold. The adviser files it within 60 days of the end of a quarter in which one of these events happened:
- The fund closed an adviser-led secondary transaction, in which the adviser offers investors the choice between selling their interests and moving them into another vehicle it manages.
- Investors removed the adviser or its affiliate as general partner.
- Investors voted to end the fund's investment period or to terminate the fund.
A quarter with no event needs no filing. On early 2025 data, about 176 of these reports are filed a year.
Form PF amendments and compliance dates since 2023
Since 2023 the form has gone through three rounds of substantive amendments. Advisers still file the version in effect before the 2024 amendments, which have yet to apply to anyone.
| Adopted | Release | Main change | Compliance date |
|---|---|---|---|
| May 3, 2023 | IA-6297 | Section 5 current reports and Section 6 private equity event reports | December 11, 2023 |
| May 3, 2023 | IA-6297 | More Section 4 data from large private equity advisers, including clawbacks | June 11, 2024 |
| July 12, 2023 | IA-6344 | Section 3 changes for large liquidity fund advisers, adopted with the money market fund reforms | June 11, 2024 |
| February 8, 2024 | IA-6546 | Broad revision of Sections 1 and 2, joint with the CFTC | July 1, 2027, after four delays |
The 2024 amendments ask large hedge fund advisers for far more detail on each qualifying hedge fund, including exposures, borrowing, currency, country and industry exposure, turnover, central clearing, risk metrics, performance by strategy, portfolio liquidity and investor liquidity. They require a separate report for each fund in a master-feeder or parallel fund structure, ask advisers to identify the trading vehicles their funds use, and delete the aggregate reporting by large hedge fund advisers in the first part of Section 2. Every filer would also report more basic data, such as inflows and outflows, base currency and beneficial ownership.
Their compliance date was first set for March 12, 2025. It moved to June 12, 2025, then to October 1, 2025, then to October 1, 2026. On August 31, 2026 the SEC and the CFTC pushed it to July 1, 2027. The early delays dealt with the timing of reporting cycles, gave the industry more time and allowed a review ordered by a January 20, 2025 presidential memorandum on rules not yet in effect. The latest one gives the agencies time to finish the April 2026 proposal, so advisers do not build systems for questions that may be deleted.
The 2026 proposal to raise the filing threshold to $1 billion
On April 20, 2026 the SEC and the CFTC proposed cutting Form PF back after a review of the whole form. The main changes are:
- The filing threshold rises from $150 million to $1 billion in private fund assets under management.
- The large hedge fund adviser threshold rises from $1.5 billion to $10 billion in hedge fund assets.
- Section 6 disappears, ending quarterly event reports for all private equity advisers.
- Section 5 gives advisers the full 72 hours, drops the margin default item and the trigger for a fund unable to pay redemptions, and narrows the definition of an operations event.
- Several look-through requirements and some performance volatility questions go, and counterparty exposure reporting by large hedge fund advisers is simplified.
- A new question would identify funds active in private credit.
The effect on coverage, measured on Form PF data for the first quarter of 2025:
| Measure | Current threshold | Proposed threshold |
|---|---|---|
| SEC-registered advisers to private funds that file Form PF | 70% | 40% |
| Private fund gross assets reported on Form PF | 96% | 94% |
| SEC-registered advisers reporting as large hedge fund advisers | 26% | 9% |
| Hedge fund gross assets reported by large hedge fund advisers | 92% | 81% |
About 1,719 advisers with $150 million to $1 billion in private fund assets would stop filing. About 390 advisers with $1.5 billion to $10 billion in hedge fund assets would move from quarterly to annual filing and lose their Section 2 and Section 5 obligations. Private fund gross assets on Form PF more than tripled between 2013 and early 2025, from $8 trillion to over $25 trillion, and the agencies cite that growth to justify the higher thresholds.
Comments closed on June 23, 2026. No final rule had been adopted by the end of October 2026. The proposal provides a transition period of at least 12 months after any final rule is published in the Federal Register.
How Form PF is filed and what it costs
Form PF is filed online through the Private Fund Reporting Depository (PFRD), a part of the IARD system that FINRA operates for the SEC. Advisers log in with the IARD account they already use for Form ADV and either fill in the form on screen or upload an XML file. The filing fee is $150 for each initial filing and each periodic update, so a quarterly filer pays $600 a year and an annual filer $150. Amendments are free.
The SEC's estimates in the April 2026 proposal, made for the 2024 version of the form, put most of the cost in staff time. Each figure includes the $150 fee:
| Filing | Internal hours | Estimated cost per filing |
|---|---|---|
| Smaller adviser, first filing | 55 | $41,308 |
| Smaller adviser, annual update | 22 | $10,600 |
| Large hedge fund adviser, first filing | 380 | $260,796 |
| Large hedge fund adviser, quarterly update | 176 | $83,750 |
| Large liquidity fund adviser, quarterly update | 86 | $41,000 |
| Large private equity fund adviser, annual update | 145 | $69,025 |
Four quarterly updates put a large hedge fund adviser at about $335,000 a year. The first-filing estimates include outside help, from $10,000 for a smaller adviser to $70,000 for a large hedge fund adviser.
In June 2018 the SEC fined 13 advisers $75,000 each for failing to file Form PF over periods of several years. All 13 made the missing filings during the investigation.
Is Form PF public?
No. Under section 204(b) of the Advisers Act, the SEC cannot be compelled to disclose a Form PF report, and the reports are exempt from the Freedom of Information Act. An adviser's proprietary information, which the law defines to include its trading strategies, research methods and trading data, gets the same protection as facts found during an examination. Any agency that receives the data from the SEC must keep it confidential to the same standard, and the SEC reports to Congress every year on how it used the data.
Investors in a fund see none of its Form PF answers either. What they receive is set by the fund's documents, a gap our comparison of a hedge fund and a mutual fund sets out. Two public SEC filings sit next to Form PF:
| Filing | Who files | Public | What it shows | How often |
|---|---|---|---|---|
| Form PF | SEC-registered advisers with $150 million or more in private fund assets | No | Leverage, exposures, liquidity, counterparties, investors and performance of each private fund | Annual or quarterly, plus event reports |
| Form ADV | SEC-registered advisers and exempt reporting advisers | Yes, on the SEC's adviser search site | The firm, its fees and conflicts, and each private fund's gross asset value, minimum investment, number of investors and service providers | Annual update within 90 days of fiscal year end, plus amendments |
| Form 13F | Institutional managers with $100 million or more in qualifying US-listed securities | Yes, on EDGAR | Long positions in those securities at quarter end | Quarterly, within 45 days |
Of the three, only Form 13F shows the public what a manager holds. Our guide to reading 13F and 13D filings explains how to use it.
What the SEC publishes from Form PF
The public sees Form PF data only in aggregate. The SEC's Division of Investment Management publishes Private Fund Statistics, a report of quarterly figures that are rounded and masked so no adviser or fund can be identified, with an Excel file of the history back to 2013. The Office of Financial Research publishes hedge fund series from the same filings in its Hedge Fund Monitor.
The report for the fourth quarter of 2025 shows:
- Hedge funds held $14.4 trillion of gross assets on $6.0 trillion of net assets, about 2.4 dollars of assets for each dollar of investor capital.
- Hedge fund borrowings equaled 54.7% of gross assets, up from 46.5% two years earlier. For qualifying hedge funds the figure was 59.4%, against 50.7%.
- The 10 largest hedge funds held 19.8% of all hedge fund gross assets, and the 100 largest held 50.1%.
- Private equity funds reported borrowings of 5.7% of gross assets.
Form PF counted $8 trillion of private fund gross assets in 2013. The figure stood at $29.6 trillion at the end of 2025.
Common questions about Form PF
Is Form PF filed annually or quarterly?
Most advisers file once a year, within 120 days of their fiscal year end. Large hedge fund advisers, with at least $1.5 billion in hedge fund assets, file every quarter within 60 days, and large liquidity fund advisers, with at least $1 billion in liquidity fund and money market fund assets, file every quarter within 15 days. Large private equity advisers file annually. On top of the periodic filings, large hedge fund advisers file current reports within 72 hours of certain events, and private equity advisers file event reports within 60 days of the end of a quarter in which a reportable event occurred.
What is the difference between Form ADV and Form PF?
Form ADV is the public registration form that every SEC-registered adviser and exempt reporting adviser files. It describes the firm, its fees and conflicts, and gives basic data on each private fund, such as gross asset value, minimum investment, number of investors and service providers. Form PF is confidential, is filed only by SEC-registered advisers with at least $150 million in private fund assets, and asks for risk data: leverage, exposures, liquidity, counterparties and performance.
Do venture capital fund advisers file Form PF?
An adviser that manages only venture capital funds can operate as an exempt reporting adviser, and exempt reporting advisers do not file Form PF. A venture capital adviser that registers with the SEC and has at least $150 million in private fund assets files Section 1 once a year like any other adviser.
Where is Form PF filed?
Online, through the Private Fund Reporting Depository (PFRD), a part of the IARD system that FINRA operates for the SEC. Advisers log in with the same IARD account they use for Form ADV. Each initial filing and each periodic update costs $150, and amendments are free.
When do the 2024 Form PF amendments take effect?
Their compliance date is July 1, 2027. The SEC and the CFTC set it on August 31, 2026, after four earlier delays from an original date of March 12, 2025. Until then, advisers keep filing the version of the form in effect before the 2024 amendments. The April 2026 proposal, if adopted, would change or delete parts of the 2024 amendments before they apply.