CFTC and SEC Extend Form PF Compliance Deadline Again

The CFTC and SEC extended the compliance date for Form PF amendments that require additional disclosures for private funds. The compliance date was extended from June 12, 2025 to October 1, 2025.

The amendments to Form PF require additional disclosures, including data on a fund's assets, financing, investor concentration and performance. (See previous coverage.) 

Industry groups argued that the June compliance date did not give private fund advisers sufficient time to fully develop and troubleshoot reporting systems. They also argued that filers may require even more time to implement third-party service providers' software. (See previous coverage). The agencies stated that they also wanted to avoid reporting cycle challenges. 

Statements

SEC Chair Paul S. Atkins directed staff to undertake a "comprehensive review" of Form PF, citing "serious concerns [regarding] whether the government's use of this data justifies the massive burdens it imposes." Chair Atkins warned that rushing Form PF implementation would "increase[] the likelihood of data errors, which defeats the entire stated purpose of the form—to enhance systemic risk monitoring."

SEC Commissioner Hester M. Peirce urged reassessment of Form PF, specifically "whether the information the form collects aligns with the intended purpose of the form." She argued that "[o]verly extensive reporting requirements not only are unduly costly and invasive, but erroneously suggest that the government’s role with respect to private funds is akin to its role supervising banks, which have a government backstop." 

SEC Commissioner Mark T. Uyeda asserted that the extension was necessary to address significant shortcomings with the 2024 amendments to Form PF. He said the rulemaking "ran afoul of what 'good regulation' looks like."

SEC Commissioner Caroline A. Crenshaw criticized the last-minute decision to extend the compliance date. Ms. Crenshaw argued that the delay was granted to undo the rule in its entirety. She also also warned that the delay undercuts oversight just as policymakers are seeking to "increasingly open private markets to retail investors." She said the move "willfully blindfold[s] the Commission" and "hobbl[es] our and other financial regulators' ability to conduct more precise and effective analysis of private markets." 

CFTC Commissioner Kristin N. Johnson said that registrants have had a "significant window of time" to meet the deadline. She said that the industry groups' raised tech issues that should have been addressed and presented to the Commissions "before the eleventh hour."