SEC Further Delays Implementation Date for Revised Form PF to October 1; Announces Intent to Review Form PF’s Substance

The U.S. Securities and Exchange Commission (“SEC”)¹ further extended the compliance date for the Form PF amendments adopted on February 8, 2024, to October 1, 2025.² The revised Form PF incorporating those amendments was due to go into effect today.³

SEC Chair Paul Atkins has also directed the SEC staff to review the substance of Form PF, stating he has “serious concerns whether the government’s use of this data justifies the massive burdens it imposes.”

As a reminder, the February 8, 2024, amendments significantly change how information is reported on Form PF, including generally requiring fund structures to be reported on a disaggregated basis, and add or expand categories of information that must be reported.⁴

If you have any questions, please contact the Kirkland regulatory attorneys with whom you regularly work.

^{1. The U.S. Commodity Futures and Trading Commission jointly issued the extension. ↩}

^{2. Unless these new Form PF requirements are amended or rescinded, annual filers will transition to using the updated version of Form PF when they submit FY 2025 annual filings, due by April 30, 2026. Quarterly filers will transition to using the updated version of Form PF for filings submitted on or after October 1, 2025. ↩}

^{3. See “SEC Delays Implementation Date for Revised Form PF Allowing April 30th Filings to Use Current Form”, Kirkland AIM, dated January 30, 2025. ↩}

^{4. See “SEC Increases Burden of Private Fund Adviser Reporting on Form PF”, Kirkland AIM, dated March 7, 2024. ↩}