On September 17, 2025, the U.S. Securities and Exchange Commission (SEC), in coordination with the Commodity Futures Trading Commission (CFTC), announced a significant extension to the compliance deadline for the February 2024 amendments to Form PF. The new deadline is now October 1, 2026, giving private fund advisers more time to prepare for the enhanced reporting requirements.
What Is Form PF and Why It Matters
Form PF is a confidential regulatory filing introduced under the Dodd-Frank Act. It enables the SEC and the Financial Stability Oversight Council (FSOC) to monitor systemic risk in the private fund industry. Advisers must report detailed fund-level data, including:
- Assets under management
- Investment strategies
- Leverage and liquidity metrics
- Fund structure details (e.g., master-feeder and parallel funds)
The February 2024 amendments were designed to:
- Increase transparency and granularity of fund data
- Require separate reporting for complex fund structures
- Strengthen the SEC’s ability to assess systemic risk and investor protection
Why the Deadline Was Extended
The SEC cited several reasons for the delay:
1. Presidential Directive for Regulatory Review
On January 20, 2025, President Trump issued a memorandum directing federal agencies to review regulations not yet in effect. This prompted the SEC and CFTC to reassess the Form PF amendments for legal and policy implications.
2. Industry Feedback
Market participants raised concerns about the workability, necessity, and legal authority of the amendments. Some final rule changes were not previously subject to public comment, raising procedural red flags.
3. Avoiding Unnecessary Costs
Implementing a rule under active review could lead to wasteful investments in systems and processes that may later be revised or scrapped, costs that ultimately impact fund investors.
4. Commitment to Thoughtful Regulation
The SEC emphasised its commitment to balanced rulemaking, stating:
“Good regulation balances the benefits of information collection with the burdens imposed on those who must comply.”
What Advisers Need to Know
- Quarterly filers (e.g., large hedge fund advisers) must comply starting Q3 2026
- Annual filers will begin using the revised Form PF in 2027
- Advisers are encouraged to delay system upgrades until the final rule is confirmed
Stay Ahead of Form PF Compliance with Galaxy
At Funds-Axis, our Galaxy platform is purpose-built to simplify Form PF reporting. Whether you’re preparing for quarterly or annual filings, Galaxy ensures you’re not just compliant, but confident.
Galaxy’s Form PF Capabilities:
- Automated data aggregation & validation
- Flexible reporting for master-feeder & parallel fund structures
- Audit-ready workflows aligned with SEC requirements
- Expert support to adapt to evolving regulatory changes
