Statement Summary
The U.S. Securities and Exchange Commission (SEC) held an open meeting to discuss extending the compliance date for amendments to Form PF from June 12, 2025 to October 1, 2025. The amendments, which originally had a compliance date of March 12, 2025, impose significant reporting requirements on private fund advisers. Concerns have been raised that the current timeline does not allow adequate time for advisers to implement necessary system upgrades and ensure data accuracy, which is critical for systemic risk monitoring.
The SEC acknowledges the heavy compliance burden these amendments place on the industry and has directed staff to review Form PF comprehensively. The goal is to minimize information requests while still gaining necessary insights, ensuring that data collection serves its intended purpose without overwhelming advisers.
Original Statement
Good afternoon, ladies and gentlemen. Thank you for being here. This is an open meeting on the 11th of June 2025 of the United States Securities and Exchange Commission under the Government in the Sunshine Act. Commissioners Hester Peirce, Caroline Crenshaw, and Mark Uyeda are also present.
Today the Commission will vote on extending the compliance date for the most recent amendments to Form PF. Currently, the compliance date for these amendments is tomorrow, June 12, 2025, but I support extending the compliance date to October 1, 2025. The initial compliance date for these amendments was March 12, 2025. In January, the SEC and CFTC jointly extended the compliance date to June 12, 2025.
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. From my experience with complex technology projects, I sympathize with those points. It is evident to me that additional time is required for dialogue with filers, review of the reasonableness of the data demands, and review of the actual utility of the information collected.
The most-recent changes to Form PF will necessitate costly upgrades to internal infrastructure, increased coordination across business units, and integration with third-party vendors. These tasks are inherently complex and require extensive testing to ensure accuracy. Rushing this process increases the likelihood of data errors, which defeats the entire stated purpose of the form—to enhance systemic risk monitoring.
Form PF was first introduced in 2011 and has subsequently been amended three times, most recently in February 2024. Each time the form has been amended, it has required advisers to provide additional information and more granular data. As a result, even without the most recent amendments, Form PF imposes significant compliance burdens on the private fund industry. The complexity of the form, in addition to the ever-evolving nature of its demands, has required advisers to seek costly legal and compliance support to complete it accurately. These costs divert resources away from advisers’ core investment functions.
Therefore, in addition to our action today, I have directed the staff to undertake a comprehensive review of Form PF. I have serious concerns whether the government’s use of this data justifies the massive burdens it imposes. We should work hard to keep our information requests to a minimum, requesting only what is needed and no more. As the saying goes, “Measure twice, cut once.” While this important work is being done, private fund advisers will continue to provide a wealth of information on the prior version of Form PF.
I’d like to thank the staff of the Securities and Exchange Commission and the CFTC for their agility in responding to these concerns.
Now, I’ll turn the meeting over to Natasha Greiner, Director of the Division of Investment Management, for the staff’s recommendation.
