Extension of Amended Form PF: What You Need to Know

What happened?

The Securities and Exchange Commission (“SEC”) jointly with the Commodity Futures Trading Commission (“CFTC”), has extended the compliance date for the amendments to Form PF that were adopted on February 8, 2024. The original compliance date fell on March 12, 2025, and is now extended to June 12, 2025.

Why the extension?

Many firms were rushing to adjust to the amended Form PF in the middle of the annual filing timeline. The amendments were set to have a 12-month transition period ending on the compliance deadline of March 12, 2025. Because annual Form PF filers have 120 days from fiscal year-end to prepare and complete Form PF, firms whose fiscal year end is December 31^st have until April 30^th to complete the filing. The March compliance date created an administrative and technical burden for annual filers, who had to choose whether to file on the current Form PF early or make all the necessary changes to complete the amended Form PF and its enhanced reporting by the typical April 30^th deadline.  The extension eases those burdens by placing the compliance deadline after the annual filing timeline.

What does this extension mean for advisers?

While the extension is a welcome relief that provides more time for filers to adjust to the amended Form PF, the amendments still require SEC-registered advisers to private funds, particularly advisers to hedge funds, to report additional information on Form PF, with more granularity. Form PF filers would be wise to use this extra time to prepare.

Advisers impacted by these amendments should:

• Familiarize themselves with the amended form;
• Review current operations to ensure that required data is available; and
• Test their preparedness for the amended form’s enhanced reporting by the extended deadline of June 12, 2025.

If you have any questions about Amended Form PF, or if you need assistance with other compliance-related items, let us know and one of our regulatory experts will be in touch.