Key Takeaways

  • Today, the SEC and CFTC voted to extend the compliance date for previously adopted amendments to Form PF from June 12, 2025, to October 1, 2025.
  • The amendments at issue primarily affect hedge fund advisers, but a number of changes to the instructions and questions apply to all filers.
  • The extension is welcome news for private fund managers, as they look to develop and operationalize reporting.
  • Chairman Atkins also directed the SEC Staff to undertake a comprehensive review of Form PF, noting his concerns regarding whether the government’s use of the data justifies the burden of reporting.

On Wednesday, June 11, 2025, the Securities and Exchange Commission and the Commodity Futures Trading Commission voted to extend the compliance date for the most recent amendments to Form PF from June 12, 2025, to October 1, 2025.1 Earlier this year, the SEC and CFTC extended the initial compliance date from March 12, 2025, to June 12, 2025. Subsequently, on April 4, 2025, the SEC staff released a substantial update to its Form PF FAQs. The amendments and subsequent updates have resulted in material changes to the information that needs to be collected by private fund managers to respond to the disclosures around data on fund assets, financing, investor concentration and performance required by Form PF.2

The Commissions’ decision today reflects industry group advocacy, which called attention to the need for additional time to develop and operationalize reporting systems and compliance processes that are responsive to the evolving substantive and technical elements of revised Form PF. Chairman Atkins also directed the Staff to undertake a comprehensive review of Form PF, questioning whether the government use of the data provided in the Form justifies the significant compliance burden on firms to report the data. Chairman Atkins noted the “curtailed” rulemaking process with respect to the amendments to Form PF in supporting the Staff’s examination into whether the requested information on Form PF provides practical utility to those agencies that use the data.3

This extension is welcome news for private fund managers in light of the challenges in building out reporting, compliance and technical systems and processes to address the amended Form.

Contributors

The authors would like to thank Anna Duong-Harrison for her contributions to this OnPoint.

Footnotes

  1. For additional background, see: SEC Adopts Third Set of Amendments to Form PF, Dechert OnPoint (Mar. 2024).
  2. Investment Adviser Association, Letter to SEC Requesting Extension of Compliance Date for Form PF Amendments (May 30, 2025).
  3. Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers, SEC Release No. IA-6883 (June 11, 2025).