Dechert LLP

06/11/2025 | News release | Distributed by Public on 06/11/2025 19:12

SEC and CFTC Extend Compliance Date for Amendments to Form PF

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.

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