On June 16, 2025, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) further extended the compliance date for recent amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. The compliance date was extended from June 12, 2025, to October 1, 2025. This is the second extension of the compliance date – the SEC and the CFTC had previously extended the compliance date from March 12, 2025, to June 12, 2025.
The amendments to Form PF, adopted on February 8, 2024, include new, detailed information disclosure requirements designed to provide greater insight into private funds’ operations and strategies, improve data quality and comparability, and reduce reporting errors. The amendments also include new requirements that large hedge fund advisers (advisers with at least $1.5 billion in hedge fund assets under management) provide separate reporting for each component fund of a master-feeder arrangement[1] or parallel fund structure[2], and that advisers identify trading vehicles[3] used by reporting funds and report them on an aggregate basis.
Readers should note that SEC Chairman Paul Atkins has expressed concerns over the recent Form PF amendments and questioned whether the government’s use of the enhanced data required by the amendments justifies the “massive burden” imposed on investment advisers. Given these concerns raised by Chairman Atkins, it should not come as a surprise if the compliance deadline for these amendments is further extended beyond October 1, 2025, or if the amendments themselves are revised or rescinded before October 1, 2025.
[1] Form PF defines a “master-feeder arrangement” as an arrangement in which one or more funds invest all or substantially all of their assets in a single private fund.
[2] Form PF defines a “parallel fund structure” as a structure in which one or more private funds pursues substantially the same investment objective and strategy and invests side by side in substantially the same positions as another private fund.
[3] Form PF defines a “trading vehicle” as a separate legal entity, wholly or partially owned by one or more reporting funds, that holds assets, incurs leverage, or conducts trading or other activities as part of a reporting fund’s investment activities but does not operate a business. Form PF defines a “reporting fund” as a private fund for which the investment adviser must report information on Form PF.
