MFA Seeks Additional Delay on Form PF Requirements

The Managed Funds Association ("MFA") urged the SEC and the CFTC ("Agencies") to extend the compliance deadline for the amended private fund reporting form ("Form PF"), citing unresolved interpretive issues, technical deficiencies, and the risk of inconsistent data.

The amendments to Form PF require additional disclosures, including data on a fund’s assets, financing, investor concentration, and performance. (See previous coverage.) The Agencies first extended the compliance deadline from March 12 to June 12, 2025. (See previous coverage.) In June, they granted a further extension to October 1, 2025, citing industry concerns about insufficient time to interpret, implement, and test the new requirements. The MFA requested a twelve-month extension, to October 1, 2026, to allow advisers more time to build and test reporting systems and to give the Agencies time to evaluate whether new Form PF is consistent with its statutory purpose of monitoring systemic risk.

In its letter, the MFA said the recent extensions did not address core implementation issues. The MFA pointed to outstanding interpretive gaps (e.g., counterparty exposure, gross exposure calculations that mix notional and market values, and disaggregation in complex structures) and noted the absence of updated FAQs sufficient to drive uniform reporting. The MFA also flagged continuing problems with the XML schema and validations, explaining that advisers and service providers are encountering errors in testing while FINRA has not finalized needed fixes.

The MFA stated that moving forward on the current timetable would produce fragmented, non-comparable submissions—undermining FSOC’s ability to aggregate data—because firms would effectively have to design to one standard now, and possibly re-engineer to another, if the Commissions revise the form after their review. The association added that shifting specifications and piecemeal guidance have delayed the completion of system builds, raised costs, and introduced operational risk.

The MFA cited recent executive orders requiring agencies to reassess rules that may be overly burdensome or beyond statutory authority. The MFA pointed to Commissioner statements questioning the scope and usefulness of the amendments, arguing that new Form PF should be reevaluated on legal and cost-benefit grounds.