Over the last few years, the SEC has rolled out multiple rounds of amendments to Form PF that iteratively expanded the reporting obligations of – and corresponding compliance burden on – hedge fund managers. Operating under new leadership, however, the SEC and CFTC have backtracked and issued proposed amendments (Proposal) that would, if adopted in their current form, reduce the number of advisers required to file Form PF and, for those still obligated to file, the number of reporting requirements. When considered in their totality, the revisions reflected in the Proposal have the most significant impact on the reporting obligations of hedge fund managers, although a number of changes specifically impact private equity and other closed-end fund managers. In addition, the Proposal requests industry comments on whether to include information reporting for private credit funds. This article, the second in a two-part series, provides detailed consideration of the revisions that are most applicable to large hedge fund managers. The first article offered a high-level overview of the various changes to Form PF outlined in the Proposal, along with analysis from legal experts abouts its potential impact on the private funds industry. See “Division of Investment Management Staff Discuss Staffing, Operations, Rulemaking and Other Developments” (Jul. 31, 2025).