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On September 17, 2025, the Securities and Exchange Commission for a third time extended the compliance date for the Form PF amendments originally adopted on February 8, 2024 until October 1, 2026. In the interim, the SEC staff will reconsider the thresholds for registered investment advisers to be required to report on Form PF and the scope of the information that it collects.
As the new compliance date will be after April 30, 2026 – the annual Form PF amendment deadline for filing advisers whose fiscal year matches the calendar year—the effective compliance date for many annual Form PF filers will now be 2027. Quarterly filers, such as large hedge fund advisers, will need to be compliant with the amended (or further amended) Form PF obligations for filings relating to the third quarter of 2026. We anticipate that many registered investment advisers will likely delay updating their internal data collection processes to address the 2024 amendments until Form PF is further amended. Director of the Division of Investment Management Brian Daly indicated that the Division will use this year to ensure the update is right sized and fit for its statutory purpose.
Chairman Atkins stated that he has directed the Staff to "consider whether we can reduce the number of advisers required to file the form without meaningfully reducing the key risk and exposure information needed by the Commission and by the other FSOC member agencies." In a discussion of the length of the extension, Chairman Atkins mentioned the adage, "Measure twice cut once."
As a reminder, the 2024 amendments to Form PF would require that filing advisers report additional information about themselves and their private funds as well as break down and report separately each component fund of a master-feeder arrangement or parallel fund structure. Click here for a comparison of the previous Form PF to the revised version that will, absent further amendment or delay, apply to all Form PFs filed on or after October 1, 2026.
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