MFA Requests Further Extension on Form PF Compliance Deadline

The Managed Funds Association ("MFA") urged the SEC and the CFTC to further delay the compliance date on new requirements to private fund reporting ("Form PF"), citing operational burdens and ongoing regulatory changes. 

The amendments to Form PF require additional disclosures, including data on a fund's assets, financing, investor concentration, and performance. (See previous coverage.) The SEC and CFTC had previously extended the compliance deadline for the amended Form PF from March 12, 2025, to June 12, 2025. (See previous coverage.) The MFA requested a twelve-month extension—from June 12, 2025, to June 2026—to allow private fund advisers time to finalize and test reporting systems while also enabling the Commissions to assess whether New Form PF aligns with its original mandate of monitoring systemic risk.

In its letter to the agencies, the MFA stated that, while the current extension addressed timing conflicts for annual and mixed filers, it failed to resolve broader operational and technological challenges faced by quarterly filers. Further, MFA argued that the extension period has been used by regulators to "[m]ake additional changes to the New Form PF," update the XML reporting schema, and issue new interpretive guidance, which should extend the time period required to come into compliance with the amendments.

The MFA emphasized that the changes, while sometimes helpful, continue to shift expectations and "are delaying the finalization of a systems build." The Association stated that technical amendments adopted in March 2025 and the evolving XML schema introduced by FINRA have required firms to repeatedly reevaluate their compliance processes. MFA also cited FAQs issued as recently as April as further complicating preparations, asserting that even small adjustments to Form PF "can cause significant changes to the data that needs to be collected."

The MFA also highlighted recent Executive Orders signed by President Trump, which call for a "regulatory freeze," promote "lawful governance," and aim to reduce "anti-competitive regulatory barriers." MFA argued that these directives require agencies to reassess rules that may be unlawful or impose "significant, unjustified costs and burdens" on market participants without meaningful benefit. According to MFA, the new amendments to Form PF "fundamentally rewrite" its purpose beyond systemic risk monitoring and introduce disproportionate reporting obligations. MFA urged the Commissions to conduct a thorough review of the amended Form PF’s legal foundation and cost-benefit justification before enforcing compliance.