On September 17, 2025, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) once again extended the compliance date for recent amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. This time, the compliance date was extended from October 1, 2025 to October 1, 2026. This is the third extension of the compliance date – the SEC and the CFTC had previously extended the compliance date from March 12, 2025 to June 12, 2025, and from June 12, 2025 to October 1, 2025. Per Commissioner Mark Uyeda, the latest extension affords the SEC and the CFTC time to conduct a review of the Form PF amendments to determine whether they raise substantial questions of fact, law, or policy. Commissioner Caroline Crenshaw expressed a more pessimistic view of the latest extension – stating that this extension suggests that the SEC is buying time to write the amendments out of existence before they ever take effect.
For additional information regarding the Form PF Amendments, see our legal update available here.
