SEC Delays Implementation Date for Revised Form PF Allowing April 30th Filings to Use Current Form

The U.S. Securities and Exchange Commission¹ extended the compliance date for the Form PF amendments that were adopted on February 8, 2024. The new compliance date is June 12, 2025. Therefore, annual filers will submit their 2024 annual amendment filings, due by April 30, 2025, on the current version of Form PF.²

As a reminder, the February 2024 amendments significantly change how information is reported on Form PF, including generally requiring fund structures to be reported on a disaggregated basis, and add or expand categories of information that must be reported.³

Please note the extension does not impact the May 2023 amendments, which contain certain event-based and broadened information reporting requirements.⁴

If you have any questions, please contact the Kirkland regulatory attorneys with whom you regularly work.
 

^{1. The Commodity Futures Trading Commission jointly issued the extension. ↩}

^{2. Quarterly filers will transition to using the updated version of Form PF for filings submitted on or after June 12, 2025. ↩}

^{3. See “SEC Increases Burden of Private Fund Adviser Reporting on Form PF,” Kirkland AIM, dated March 7, 2024. ↩}

^{4. See “SEC Adopts Significant Amendments to Private Fund Adviser Reporting on Form PF,” Kirkland AIM, dated May 5, 2023. ↩}