Compliance Date for Amendments to Form PF Extended Again
On June 11, 2025, the SEC and the CFTC voted to extend the compliance date for amendments to Form PF for a second time, resulting in a new compliance date of October 1, 2025. Form PF is the confidential reporting form filed by certain SEC-registered private fund investment advisers, including those that also are registered with the CFTC as commodity pool operators or commodity trading advisers, to report confidential information about the private funds that they advise. The amendments to Form PF were adopted on February 8, 2024 with an original compliance date set for March 12, 2025. On January 29, 2025, the SEC and the CFTC extended the compliance date of the Form PF amendments to June 12, 2025 in order to address certain challenges associated with the timing of reporting cycles for Form PF. In extending the compliance date to October 1, 2025, the SEC and the CFTC cited the persistence of the conditions that led to the first extension of the compliance date and stated that extending the compliance date to October 1, 2025 will provide more time for filers to develop and test their Form PF reporting systems, which will help improve the quality of data reported.
The joint final rule extending the compliance date is available here, and the related SEC press release is available here.
Vedder Thinking | Articles Compliance Date for Amendments to Form PF Extended Again
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June 27, 2025
On June 11, 2025, the SEC and the CFTC voted to extend the compliance date for amendments to Form PF for a second time, resulting in a new compliance date of October 1, 2025. Form PF is the confidential reporting form filed by certain SEC-registered private fund investment advisers, including those that also are registered with the CFTC as commodity pool operators or commodity trading advisers, to report confidential information about the private funds that they advise. The amendments to Form PF were adopted on February 8, 2024 with an original compliance date set for March 12, 2025. On January 29, 2025, the SEC and the CFTC extended the compliance date of the Form PF amendments to June 12, 2025 in order to address certain challenges associated with the timing of reporting cycles for Form PF. In extending the compliance date to October 1, 2025, the SEC and the CFTC cited the persistence of the conditions that led to the first extension of the compliance date and stated that extending the compliance date to October 1, 2025 will provide more time for filers to develop and test their Form PF reporting systems, which will help improve the quality of data reported.
The joint final rule extending the compliance date is available here, and the related SEC press release is available here.