June 13, 2025
What Happened?
On June 11, 2025, the Securities and Exchange Commission (“SEC”), jointly with the Commodity Futures Trading Commission (“CFTC”), voted to further extend the compliance date for the amendments to Form PF that were adopted on February 8, 2024. The original compliance date that fell on March 12, 2025, was first extended to June 12, 2025, and is now extended to October 1, 2025.
This second extension gives firms more time to adjust to the amended Form PF. On February 8, 2024, the SEC adopted new amendments to Form PF that build on those adopted in May and July of 2023. The amendments were set to have a 12-month transition period ending on the compliance deadline of March 12, 2025. The first extension kept this transition from ending during the annual Form PF filing period for firms with a December 31st fiscal year end. The second extension will give filers and service providers additional time to develop the necessary reporting for the amended Form PF.
What does this mean for me?
Commissioner Peirce dissented to the original adoption of the amendments to Form PF. In her statement on the further extension, she noted that the new form “is not ready for prime time” and said, “[we] should reassess whether the information the form collects aligns with the intended purpose of the form.” As we work towards the extended compliance date, we will have to wait and see if a review of Form PF under Chairman Atkins will lead to further changes and possibly a simpler form.
