Form PF update
Further SEC extension – June 12th compliance date extended
On June 11th, the SEC convened and voted to extend the compliance deadline for the amended Form PF reporting requirements from June 12th 2025, to October 1st 2025 at the earliest.
Key concerns raised
According to the Commission, private fund advisers need more time to interpret, implement, and test the complex technical and operational changes required by the amendments to ensure accurate and consistent reporting. While this was not the unanimous opinion of the Commissioners, the vote to extend the implementation was passed 3 to 1.
The Commission cited concerns of private fund managers around the need for costly upgrades to internal systems and co-ordination across business units and third-party vendors. Speakers at the meeting raised concerns about technical shortcomings and ambiguities in the revised requirements, particularly around disaggregated reporting. It was acknowledged that the compliance burden is already significant, and the new amendments exacerbate this without clear evidence that the benefits outweigh the costs.
Looking ahead…
It appears increasingly likely that the SEC will undertake a broader review of the amendments to assess whether they effectively support supervisory objectives. The tone of the meeting suggested a degree of reflection on whether the amendments had been fully considered. For now, filers will continue to use the existing Sections 1 and 2, but it would not be surprising to see the October 1st date extended again and possibly the proposed amendments significantly revised. This development will no doubt come as a relief for some, while frustrating others who have already invested considerable resources in preparing for the original deadline. Addition Compliance will continue to closely monitor regulator and industry discussions on this and keep our clients up to date.
