On January 29th, the Securities and Exchange Commission and the Commodity Futures Trading Commission (CFTC) jointly extended the compliance date for the amendments to Form PF. Adopted on February 8, 2024, this is the confidential reporting form for certain SEC-registered investment advisers to private funds, including those that also are registered with the CFTC as commodity pool operators (CPOs) or commodity trading advisers (CTA).
The original compliance date for these amendments, March 12, 2025, has been extended to June 12, 2025. This extension applies only to the compliance date; the final rule’s effective date remains March 12, 2025. The extension is intended to mitigate certain administrative and technological burdens and costs connected to the original compliance date. The extension also provides filers with additional time to program and test for compliance with these amendments.
The adopted amendments to Form PF implemented these changes in February 2024:
- updated the way advisers report complex structures by requiring advisers to report separately each component fund in complex fund structures (including master-feeder arrangements and parallel fund structures)
- approved a rule under the Investment Advisers Act to revise instructions for requesting a temporary hardship exemption
- eliminated aggregate reporting for large hedge fund advisers by removing the current aggregate reporting requirement
- enhanced the Financial Stability Oversight Council’s ability to monitor systemic risk
- enhanced reporting regarding hedge funds by removing redundant questions and requiring more detailed information about hedge fund investment strategies, counterparty exposures, and trading and clearing mechanisms
- enhanced reporting on basic information about advisers and the private funds they advise by requiring advisers to report additional information about themselves and their private funds
- enhanced reporting by large hedge fund advisers on qualifying hedge funds (hedge funds that have a net asset value of at least $500 million)
Sources:
SEC Adopts Amendments to Enhance Private Fund Reporting (sec.gov)
Final Rule—Extension of Compliance Date (sec.gov)