On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the amendments to Form PF that were adopted on February 8, 2024. The compliance date for these amendments, which was June 12, 2025, has been extended to October 1, 2025. The purpose of the extension is to provide more time for filers to program and test for compliance with the amendments, which, among other things, expand the list of investor classifications that Form PF filers are required to report. Accordingly, Form PF filers may continue to file the current Form PF until October 1, 2025.
In further developments, SEC Chairman Paul Atkins recently called for reassessment of the new reporting rules under the amended Form PF. Atkins has expressed concerns about whether the burdens imposed on fund managers by the new Form PF amendments are justified by their utility to regulators. Given Atkins’ comments, existing Form PF filers, and investment managers reasonably expecting to become Form PF filers in the near future, should be aware that the amendments to Form PF may be further amended or rescinded between now and October 1, 2025.
For more information on the amendments to Form PF, please visit Foley Hoag’s client alert from April 2025.
