The SEC and CFTC have extended the compliance date for their jointly adopted amendments to Form PF (originally 12 March 2025) to 12 June 2025.
In December 2024, a number of industry associations submitted a letter to SEC and CFTC on behalf of their respective members describing certain significant technological and administrative challenges being faced by advisers required to file on new Form PF, as well as third-party vendors assisting these advisers. In the letter, these industry associations requested that the SEC and CFTC extend the compliance date for new Form PF until 12 September 2025 (or, at a minimum, until 12 June 2025), maintaining that such an extension would provide impacted industry participants with additional time to build out and test new reporting systems and work through any outstanding reporting and interpretive questions.
In granting the three-month extension until 12 June 2025, the SEC and CFTC reasoned that the extension should alleviate certain administrative and technological challenges associated with the original compliance date and that the extension would provide more time for filers to program and test for compliance with the amendments. For example, as a result of this extension, December 31 year-end filers will no longer need to report 2024 data on the new form.
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