On June 11th, 2025, the Securities and Exchange Commission (the “SEC”), together with the U.S. Commodity Futures Trading Commission (the “CFTC”) further extended the compliance date for the amendments to Form PF (the “Form PF Amendments”) until October 1, 2025. The Form PF Amendments were adopted on February 8, 2024 with an original compliance date of March 12, 2025, before being first extended to June 12, 2025 as discussed in the SEC’s prior Press Release.

In deciding to extend the deadline for the Form PF Amendments again, Chairman Paul S. Atkins stated in his statement that “notwithstanding the prior three-month compliance extension, we have received credible commentary that the current timeline simply does not provide private fund advisers with sufficient opportunity to interpret, implement, and test their systems to ensure accurate and consistent reporting.” In addition to this extension, Chairman Atkins has also directed the SEC staff to undertake a more comprehensive review of Form PF to ascertain whether the government’s use of this data justifies the large compliance burdens that it imposes on the private fund industry.

As a result of this extension, private fund advisers should continue to provide information regarding their private funds using the existing version of Form PF.

Please contact an attorney in the Investment Management Group at Seward & Kissel LLP if you have any questions regarding this extension or on Form PF in general.