News & Analysis as of

Securities and Exchange Commission (SEC) Form PF Reporting Requirements

Polsinelli

SEC and CFTC Further Delay Form PF Compliance Date to October 1, 2025

Polsinelli on

On June 11, 2025, the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have once again delayed the compliance date for the amendments to Form PF, moving it to October 1, 2025....more

Foley Hoag LLP

SEC Extends Compliance Date for Form PF Amendments to October 1, 2025

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On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the amendments to Form PF that were adopted on February 8, 2024. The compliance date for these amendments, which was...more

Seward & Kissel LLP

Extension of Form PF Amendments Compliance Date

Seward & Kissel LLP on

On June 11th, 2025, the Securities and Exchange Commission (the “SEC”), together with the U.S. Commodity Futures Trading Commission (the “CFTC”) further extended the compliance date for the amendments to Form PF (the “Form PF...more

Katten Muchin Rosenman LLP

SEC Form PF Amendments Delayed Again

Yesterday, the Securities and Exchange Commission (SEC) voted to extend the compliance date for rule amendments that expand the reporting requirements for private fund managers. The Form PF amendments were adopted on February...more

Proskauer - Regulatory & Compliance

SEC Further Extends Form PF Compliance Date and Signals Broader Reconsideration

On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the most recently adopted amendments to Form PF by approximately four months, to October 1, 2025....more

K&L Gates LLP

United States: STOP! START AGAIN! JUST KIDDING, STOP AGAIN! SEC Provides 11th Hour Extension of Compliance Date for Amended Form...

K&L Gates LLP on

With less than a day to go before the 12 June 2025 compliance date for the SEC and CFTC’s jointly adopted amendments to Form PF, the SEC, together with the CFTC, voted today to further extend the compliance date for the...more

Paul Hastings LLP

SEC Updates Marketing Rule and Form PF FAQs in Short Succession

Paul Hastings LLP on

On March 19, the SEC issued updates to its FAQs regarding compliance with Rule 206(4)-1 of the Advisers Act (the Marketing Rule) addressing (i) when gross and net performance are required for certain “extracted” performance,...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

Vedder Price

Third Set of Form PF Amendments Take Effect on June 12, 2025

Vedder Price on

On February 8, 2024, the SEC adopted its third set of amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. The amendments specifically affect Sections 1 and 2...more

Mayer Brown Free Writings + Perspectives

SEC and CFTC Extend Compliance Deadline for Form PF Amendments

The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have extended the compliance deadline for the amendments to Form PF, moving it from March 12, 2025 to June 12, 2025....more

Proskauer Rose LLP

SEC and CFTC Extend Compliance Date for Form PF Amendments

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On January 29, 2025, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (together, the “Agencies”) jointly announced that the compliance date for the new Form PF would be extended by three...more

SEC Compliance Consultants, Inc. (SEC³)

Lessons From 2024: Tips for Private Fund Managers

As we look back on the SEC’s actions in 2024, we wanted to share our thoughts on lessons learned that we believe will carry through to 2025....more

Carlton Fields

SEC and CFTC Amend Form PF … Again: Private Fund Advisers Should “Kick the Tires” Before Next Race to File

Carlton Fields on

In February 2024, the SEC and the Commodity Futures Trading Commission (CFTC) adopted major amendments to Form PF to provide greater transparency into the operations and strategies of private funds, and to assist the...more

Morgan Lewis

SEC and CFTC Adopt Amendments to Form PF

Morgan Lewis on

On February 8, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC and, together with the SEC, the Commissions) voted to adopt amendments to Form PF1 that will impact the...more

WilmerHale

CFTC Year in Review: 23 Takeaways From 2023 and Predictions for 2024

WilmerHale on

At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more

Katten Muchin Rosenman LLP

Third Time's a Charm? SEC & CFTC Finalize Amendments to Form PF

On February 8, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) jointly adopted amendments to Form PF, the confidential reporting form for certain registered investment advisers to...more

Dorsey & Whitney LLP

RIA Regulatory Review - October 2023

Dorsey & Whitney LLP on

This RIA Regulatory Review highlights certain key regulatory developments affecting investment advisers. Please contact us with any questions on the topics covered below. The SEC Adopts Significant New Rules for Private...more

Vedder Price

SEC Adopts Significant Money Market Fund Reforms and Amended Form PF Reporting Requirements for Private Liquidity Fund Advisers

Vedder Price on

On July 12, 2023, in a 3-2 vote, the SEC adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, representing the SEC’s latest reforms of the rules governing money market funds in its effort to improve their...more

Blank Rome LLP

Regulatory Update and Recent SEC Actions - July 2023

Blank Rome LLP on

REGULATORY UPDATES - Recent SEC Leadership Changes - The Securities and Exchange Commission (the “SEC”) announced the appointment of Deborah J. Jeffrey as Inspector General effective May 7, 2023. Prior to this...more

Kilpatrick

SEC Adopts Amendments to Form PF

Kilpatrick on

On May 3, 2023, the Securities and Exchange Commission (the “SEC”) adopted a new rule (the “Rule”) that amends Form PF, the confidential reporting form for certain SEC-registered investment advisers to privately-offered...more

Hogan Lovells

SEC adopts overhaul to Form PF, requiring more frequent reporting for some advisers

Hogan Lovells on

The U.S. Securities and Exchange Commission (SEC) adopted final amendments to Form PF, the confidential reporting form required for certain SEC-registered investment advisers (RIAs) to private funds, on 3 May 2023. The...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

SEC Adopts Amendments to Form PF

On May 3, 2023, the SEC adopted amendments to Form PF, the confidential reporting form filed by certain SEC-registered investment advisers. The amendments are an effort to improve the ability of the Financial Stability...more

Faegre Drinker Biddle & Reath LLP

SEC Adopts Amendments to Form PF

The U.S. Securities and Exchange Commission (the SEC) adopted Amendments to Form PF (the Amendments) in a three-to-two vote on May 3, 2023, over a decade after Form PF’s initial adoption. SEC Chair Gary Gensler predicted that...more

Groom Law Group, Chartered

What Plan Fiduciaries Should Know About SEC’s Final Form PF Amendments

On May 3, 2023, the Securities & Exchange Commission (“SEC”) adopted amendments to Form PF (the “Final Amendments”).  Plan fiduciaries that utilize private equity funds, and regulated entities that serve these plan sponsors,...more

Latham & Watkins LLP

SEC Adopts Changes to Form PF for Private Equity and Large Hedge Fund Advisers

Latham & Watkins LLP on

On May 3, 2023, the US Securities and Exchange Commission (SEC), in a 3-2 decision, adopted a final rule that modifies Form PF’s reporting requirements for certain registered investment advisers to private equity funds, hedge...more

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