Lauren Ford

On April 20, 2026, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) jointly proposed amendments to Form PF, the confidential reporting form filed by certain SEC-registered investment advisers to private funds. The proposal is intended to eliminate filing requirements for smaller advisers, reduce certain reporting obligations for smaller hedge fund advisers, streamline and simplify other reporting requirements, and make corrections and other revisions.

In December 2025, the Staff of the U.S. Commodities Futures Trading Commission (“CFTC”) issued a no-action letter (the “Letter”) that effectively reinstates the former Rule 4.13(a)(4) exemption from registration as commodity pool operators (CPOs) or commodity trading advisers (CTAs) for certain SEC-registered investment advisers with respect to commodity pools offered solely to qualified eligible persons (the “QEP Exemption”). The CFTC had rescinded the QEP Exemption in 2012.

Following the Fifth Circuit's 2024 vacatur of the SEC’s Private Fund Rules[1], registered investment advisers must again rely on enforcement precedent to understand prohibited preferential treatment practices.