SEC Extends Form PF Amendments Compliance Date

 The SEC yesterday, together with the CFTC, extended the compliance date for amendments to Form PF that were adopted on Feb. 8, 2024. The compliance date for these amendments, which was originally March 12, 2025, has now been extended to June 12, 2025. The practical impact of the extension is that annual filers will not be required to comply with the amendments until at least April 2026.
 
The SEC explained that the extension was appropriate to address concerns that had been raised by the industry, including inadequate time to program and test for compliance with the amendments and the administrative and technological burdens and costs associated with the prior compliance date.
 
The amendments once effective will require the following:

• All Filers: separate reporting for each component fund of a master-feeder arrangement and parallel fund structure (Form PF currently permits master-feeders and parallel funds to be reported separately or in the aggregate at the option of the filer).

• All Filers: additional information related to the adviser and its related persons, assets under management, withdrawal and redemption rights, gross asset value and net asset value, inflows and outflows, base currency, borrowings and types of creditors, fair value hierarchy, beneficial ownership, and fund performance.

• All Hedge Fund Advisers: more detailed reporting about hedge fund investment strategies (including digital asset strategies), counterparty exposures, and trading and clearing mechanisms employed by hedge funds.

• Large Hedge Fund Advisers: enhanced or new reporting on investment exposures, open and large position reporting, market factor effects, currency exposure, turnover, country and industry exposure, CCP reporting, risk metrics, investment performance by strategy, portfolio liquidity, and financing and investor liquidity.