On September 17, 2025, the Securities and Exchange Commission (the “SEC”), together with the U.S. Commodity Futures Trading Commission (the “CFTC”, and together with the SEC, the “Commissions”) further extended the compliance date for the amendments to Form PF (the “Form PF Amendments”)1 until October 1, 2026. The Form PF Amendments were adopted on February 8, 2024 with an original compliance date of March 12, 2025. Since then, the compliance date was first extended to June 12, 2025 and subsequently to October 1, 2025, as discussed in the SEC’s January 2025 Press Release and June 2025 Press Release.
The Form PF Amendments require private fund advisers to report more details related to their businesses including, but not limited to, their assets under management, withdrawal rights, performance, and strategies. The Form PF Amendments also require individual reporting of each fund in a master-feeder or parallel fund structure and any trading vehicles owned by a reporting fund. Additionally, large hedge fund advisers (those with a net asset value of at least $500 million) have additional enhanced reporting requirements under the Form PF Amendments.
As a result of this extension, private fund advisers should continue to provide information regarding their private funds using the existing version of Form PF.
1 Release No. IA-6546, Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (February 8, 2024).
