SEC and CFTC Extend Form PF Compliance Date for Recent Form PF Amendments to June 12, 2025

On January 29, 2025, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) announced a three-month extension of the compliance date for the new Form PF amendments, moving the deadline from March 12, 2025, to June 12, 2025.[1] This extension provides private fund advisers additional time to implement the operational and technological changes required under the updated Form PF reporting framework adopted on February 8, 2024. The agencies’ decision to extend the deadline to June 12, 2025, helps address the challenges associated with the Form PF filing cycle while ensuring that regulators obtain important data beginning with the second quarter of 2025.

The recent Form PF amendments significantly expand the scope of information required from all private fund advisers, increasing disclosure obligations, particularly for large hedge fund advisers and those with complex fund structures, as highlighted in Crowell & Moring’s Client Alert Form PF Compliance Amid Recent SEC Enforcement Actions and Upcoming Deadlines.

Key Compliance Dates and Industry Impact

The initial compliance date of March 12, 2025, fell after the fourth-quarter 2024 filing deadlines for many quarterly reporting funds (January 15, 2025, or March 1, 2025, depending on the type of private fund) but before the 2024 annual filing deadline for many annual reporting funds (April 30, 2025, for advisers with a December 31 fiscal year-end). The differences between the current Form PF and the final Form PF—including distinct questions and variations in data computation—create additional burdens for private fund advisers. These challenges are further complicated by the simultaneous efforts of private fund advisers and third-party vendors to develop reporting systems for the new Rule 13f-2 and related Form SHO, which require certain institutional investment managers to report short sale-related information to the SEC. Compliance with these new rules began on January 2, 2025, with the first report due on February 14, 2025.

Several industry groups had requested that the SEC and CFTC extend the compliance date to September 12, 2025, or alternatively, to June 12, 2025.[2] Without the extension, many private fund advisers would have had to report 2024 data under both versions, submitting an initial filing under the current Form PF for their quarterly reporting funds’ fourth-quarter 2024 data and then submitting an amendment under the final Form PF for their annual reporting funds’ 2024 fiscal year data. This dual-reporting requirement would have introduced significant technological and administrative challenges. The extension mitigates these burdens by providing additional time for programming and testing compliance with the final Form PF’s requirements and collecting the necessary data.

The SEC and CFTC cited technological and administrative hurdles as primary reasons for the extension, acknowledging industry concerns about firms’ readiness to comply with the new requirements. Notably, the SEC has yet to release the XML schema necessary for preparatory test filings, which likely influenced the decision to grant additional time. While industry participants had advocated for a longer delay—proposing a September 12, 2025 deadline—the agencies ultimately balanced these requests against the regulators’ need for enhanced fund data.

Next Steps for Private Fund Advisers

Private fund advisers should use this additional time to finalize internal preparations, enhance reporting infrastructure, and ensure readiness for the expanded Form PF requirements. The extension offers an opportunity to address outstanding interpretive questions regarding the new data requests and resolve technological challenges, including deficiencies in the technical specifications released by IARD. If you have any questions or would like to discuss this Client Alert, please contact Crowell & Moring LLP for further guidance on the implications of this extension.