Today, the U.S. Securities and Exchange Commission (SEC) voted to extend the compliance date for the February 8, 2024 Form PF amendments to October 1, 2025, contingent on corresponding action by the Commodity Futures Trading Commission (CFTC), which is expected to vote on this soon.
This joint extension, once confirmed, will override the previous compliance extension deadline of June 12, 2025.
Context and Considerations
The extension was nearly fully supported by the by the SEC Commissioners, with only one dissent. In remarks during the meeting, SEC Chairman Paul Atkins acknowledged that the additional time may be used to re-evaluate the amendments and their implementation, potentially leading to further modification.
A public statement issued by Commissioner Hester Peirce highlights the rationale behind the extension, including the desire to provide market participants with clarity, operational efficiency, and regulatory alignment.
What This Means for Private Fund Advisers
Private fund advisers subject to the Form PF amendments—particularly those managing $150 million or more in private fund assets—should continue to regard this announcement as an extension.
-
Preparation should continue, albeit at a measured pace. Firms should continue to assess system readiness, data sourcing, and reporting workflows.
-
The additional time offers an opportunity to evaluate compliance strategies. This may include technical testing of XML schema updates or review of evolving internal controls.
-
Regulatory monitoring remains essential. Future changes are possible, and the regulatory environment continues to evolve.
Staying Informed
At iQuant Solutions, we are committed to helping clients maintain alignment with current compliance expectations while remaining agile in the face of regulatory developments.
We will continue to monitor updates from both the SEC and CFTC and provide further analysis as additional information is released in the coming months.
For a detailed overview of the amended Form PF requirements and our prior commentary, please see our earlier publications from May 13, 2025 and February 5, 2025.
To speak with our regulatory oversight team or learn more about how iQuant Solutions supports Form PF compliance, contact us.
