On 29 January 2025, the United States Securities and Exchange Commission (US SEC) and the United States Commodity Futures Trading Commission (US CFTC) announced an extension of the compliance date for amendments to US Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers. The compliance deadline, initially set for 12 March 2025, has now been moved to 12 June 2025. The decision follows concerns raised by industry participants regarding the administrative and technological challenges associated with the original timeline.
The US Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers is a confidential reporting form used by certain US SEC-registered investment advisers, including those also registered with the US CFTC as commodity pool operators (CPOs) or commodity trading advisers (CTAs). The form requires private fund advisers to provide data on their operations, financial condition, and risk exposure. These amendments, originally adopted on 8 February 2024, aim to enhance the oversight of hedge funds and other private funds to support regulatory monitoring and systemic risk assessment. The extension provides additional time for affected entities to implement necessary changes and comply with the updated reporting requirements.
The US Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers was introduced following the United States Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, with the aim to improve regulatory oversight by requiring private fund advisers to disclose information relevant to financial stability and investor protection. Amendments to the form were adopted in February 2024 to refine reporting requirements and capture more detailed data on large hedge funds and other private investment entities.
The compliance deadline extension was prompted by industry concerns regarding operational burdens. The changes require private fund advisers to adjust their reporting systems, which involves significant technological modifications. Market participants argued that meeting the original compliance date would result in overlapping regulatory obligations, as it fell within an already demanding reporting period.
Background
On 8 February 2024, the US SEC and US CFTC adopted amendments to US Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers to enhance reporting transparency and improve risk assessment capabilities. The amendments were initially scheduled to take effect on 12 March 2025, giving advisers a year to update their systems. However, as the compliance date approached, industry groups, including the Managed Funds Association, Alternative Investment Management Association, Investment Adviser Association, and SIFMA Asset Management Group, submitted requests for an extension.
These groups raised the complexity of the required changes and the risk of inconsistencies if private fund advisers had to file reports under both the current and amended versions of Form PF within the same reporting cycle. The industry suggested an extension to either 12 June 2025 or 12 September 2025. After reviewing these concerns, the regulators decided on a three-month extension, concluding that it would alleviate the most pressing issues while still ensuring that the new reporting requirements come into effect without undue delay.
The extension allows private fund advisers additional time to adjust their reporting systems and conduct necessary testing to comply with the new Form PF requirements.
The updated reporting requirements under US Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers will enhance the ability of the United States Financial Stability Oversight Council to monitor potential systemic risks and improve the US SEC’s regulatory oversight of private funds, address data quality issues, streamline reporting obligations, and refine the assessment of market trends. The revised compliance date means that private fund advisers must now adhere to the updated Form PF requirements by 12 June 2025.
(Source: https://www.sec.gov/newsroom/press-releases/2025-33, https://www.sec.gov/files/rules/final/2025/ia-6838.pdf)
