Letter to SEC on Proposed Amendments to Form PF

June 23, 2026

Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: Form PF; Reporting Requirements for All Filers (Release No. IA-6959; File No. S7-2026-13)

Dear Ms. Countryman:

The Virginia Society of CPAs (VSCPA) Accounting & Auditing Advisory Committee has reviewed the Exposure Draft (ED) — Form PF; Reporting Requirements for All Filers (Release No. IA-6959; File No. S7-2026-13), issued by the Securities and Exchange Commission’s and Commodity Futures Trading Commission’s proposed amendments to Form PF. The VSCPA is the leading professional association in Virginia dedicated to enhancing the success of all CPAs and their profession by communicating information and vision, promoting professionalism, and advocating members’ interests. The VSCPA membership consists of nearly 11,000 individual members who actively work in public accounting, private industry, government, and education.

We appreciate the Commission’s objective of reducing compliance burdens; however, based on our review, we do not believe the proposal sufficiently demonstrates that the benefits of reduced reporting requirements outweigh the potential risks associated with decreased reporting and regulatory visibility. We agree that the proposal to increase the reporting thresholds and to reduce requisite reporting information ostensibly will lower compliance costs; additional empirical analysis is required to support the conclusion that these changes would not impair stakeholders’ ability to identify, monitor, and respond to emerging risks. Specifically, we encourage the Commission to:

• Provide further support for the proposed threshold increases, including discussion of how the proposed framework would continue to identify risks that may arise from entities no longer subject to existing Form PF reporting,
• Expand the analysis beyond asset-based coverage metrics to address broader risk identification, and
• Quantify the expected benefits, including compliance cost savings and operational efficiencies.

Transparency and access to reliable information are critical to effective oversight and market confidence. Accordingly, sufficient evidence should support the implicit assertion that the information eliminated is no longer necessary, or that alternative mechanisms provide comparable regulatory insight. Before finalizing the proposal, we encourage the Commission to provide more robust analysis of the expected benefits, potential risks, and overall impact on transparency and regulatory oversight.

The VSCPA appreciates the opportunity to respond to this ED. Please direct any questions or concerns to VSCPA Vice President, Advocacy & Pipeline Emily Walker, CAE, at ewalker@vscpa.com or (804) 612- 9428.

Sincerely,

Elissa Obillo, CPA
Chair 2026-2027
VSCPA Accounting & Auditing Advisory Committee 

VSCPA Accounting & Auditing Advisory Committee 2026-2027

Elisa Obillo, CPA — Chair
Domenic Savini, CPA — Vice Chair
Scott Cohen, CPA
Jonathan Head, CPA
Clarissa Hoffman, CPA
Joshua Keene, CPA
Daniel Martin, CPA
John McIntosh, CPA
Kendra Morgan, CPA
Brook Peterson, CPA
Michael Phillips, CPA
Amy Stokes, CPA
Clara Tang, CPA
Charles Valadez, CPA
Anna Wagner, CPA
Patrick Wunderlich, CPA
Natalya Yashina, CPA