Challenges of the Amended Form PF June 12, 2025, Compliance Deadline

The amendments to Form PF that the SEC and CFTC jointly issued on February 8, 2024, mandated significantly more granular reporting from hedge fund managers with respect to a number of key operational features, such as the risk exposures and positions of large funds; disaggregated fund data; trading vehicles; withdrawal rights; and digital assets, among other areas. These amended requirements were originally set to take effect as of March 12, 2025, but in January 2025, the SEC and CFTC extended the compliance deadline three months to June 12, 2025. This article examines why an extension of the original compliance deadline was needed; delves into those aspects of the amended form that have proven especially complex or problematic for fund managers and why; looks at the role of third-party administrators in compliance efforts; and considers the possibility that regulators might repeal some or all of the new filing requirements under a more pro-business presidential administration. For more information on the Form PF amendments, see our two-part series: “Third Round of Form PF Amendments Focuses on Granular Hedge Fund Data” (Jun. 6, 2024); and “Key Takeaways From the Latest Round of Form PF Amendments” (Jun. 20, 2024).

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