Form PF has been around for well over a decade. However, ongoing amendments to the reporting form for private fund advisers have made compliance a moving target.
Current Form PF requirements
Form PF and all its amendments made prior to February 2024 remain in effect, and all private fund advisers subject to Form PF are obligated to comply. As SEC officials stated in recent compliance deadline extensions, the February 2024 amendments require significantly increased reporting burdens, and firms are likely to need extended time to develop and test their reporting systems.
As of September 17, 2025, the SEC’s newest Form PF compliance deadline is October 1, 2026, giving advisers another year to prepare.
SEC official statements on a review of Form PF merit continued attention.
During the SEC’s open meeting on June 11, 2025, commissioners were split in their support of the deadline extension. The dissenting commissioner suggested that the extension was not truly intended to allow firms more preparation time to comply with the February 2024 amendments but rather to broadly review them. She stated her concern that “we will continue to accommodate requests to extend this compliance date until we have significantly revised or undone this rule.”
These statements do not indicate that changes to Form PF are imminent or certain, only that private fund advisers should remain attuned to future SEC actions as they prepare for the October 1, 2026, deadline.
Timeline of Form PF amendments
1. July 2014 Form PF change to support money market fund reforms
The SEC adopted its first amendments to Form PF in a July 2014 rulemaking package in conjunction with money market fund reforms. The overarching goal was to reduce systemic risk in money market funds through structural and operational reforms. At the same time, the SEC amended Form PF to monitor the potential impact of the money market reforms.
Money market fund reforms
Separate from Form PF changes, the SEC:
- Removed the valuation exemption for non-governmental institutional money market funds that allowed them to maintain a stable $1.00 net asset value (NAV). Regulators determined that the stable NAV decreased the funds’ risk transparency, exposing them to heavy investor redemptions amid periods of stress.
- Gave money market fund boards the ability to impose a liquidity fee and “gate” funds (suspend redemptions) if their fund’s weekly liquidity level falls below the required regulatory threshold.
- Required money market funds to increase their portfolio diversity, enhance stress testing, and improve transparency through additional reporting to the SEC and investors.
Form PF additions for unregistered liquidity funds
Noting that unregistered liquidity funds can resemble money market funds in their efforts to maintain a stable NAV, the SEC began requiring advisers to certain large liquidity funds to report additional information on Form PF. The change aimed to enable the SEC to monitor potential shifts from money market funds into unregistered liquidity funds, resulting from the money market reforms, and to understand any associated risks.
Critical dates
- Adoption date: July 23, 2014
- Effective date: October 14, 2014
- Compliance date: April 14, 2016 for Form PF amendments
2. May 2023 Form PF amendments and event-based reporting
Nearly a decade after the first Form PF amendments, the SEC adopted its second set of amendments. The SEC designed the 2023 amendments to enhance both the Financial Stability Oversight Council’s (FSOC) systemic risk monitoring and the SEC’s oversight of private fund advisers and investor protection efforts.
Form PF amendments included:
Event-based reporting additions
The SEC added requirements to Form PF for large hedge fund advisers and all private equity fund advisers to file current reports on events that could indicate significant fund stress or investor harm.
Large hedge fund event reporting requirements
For large hedge fund advisers with at least $1.5 billion in hedge fund AUM, relevant events must be reported no later than 72 hours following the event, which could include:
- Certain extraordinary investment losses
- Significant margin and default events
- Terminations or material restrictions of prime broker relationships
- Operations events
- Events associated with withdrawals and redemptions
Private equity fund event reporting requirements
All private equity fund advisers that file Form PF must report relevant events quarterly, within 60 days of the end of each quarter. Reportable events could include:
- The removal of a general partner
- Certain fund termination events
- An adviser-led secondary transaction
Annual large private equity fund reporting additions
The 2023 Form PF additions also required large private equity fund advisers with at least $2 billion in private equity AUM to file annual reports on their strategies, borrowings, and general partner and limited partner clawbacks.
Critical dates
- Adoption date: May 3, 2023
- Effective dates: June 11, 2024, except for new Form PF sections 5 and 6, effective on December 11, 2023
- Compliance date: June 11, 2024, except for new Form PF sections 5 and 6, effective on December 11, 2023
3. July 2023 additional money market fund reforms and related Form PF changes
In July 2023, the SEC made additional money market reforms related to those from 2014. Similarly to the 2014 action, the SEC concurrently amended Form PF for large liquidity fund advisers to align their reporting with the new money market fund reforms.
Additional money market fund reforms
Once again, separate from Form PF changes, the SEC made various changes to money market fund requirements, including removing fund boards’ ability to suspend redemptions and implement fees if the fund falls below a liquidity threshold, among other changes.
Additional reporting requirements for liquidity fund advisers
The SEC amended Form PF section 3 of Form PF to align with the concurrent money market reforms. The amendments aimed to provide a more complete picture of the short-term financing markets in which liquidity funds invest and improve regulators’ ability to assess and oversee short-term financing markets.
Critical dates
- Adoption date: July 12, 2023
- Effective date: June 11, 2024
- Initial compliance date: June 11, 2024
4. February 2024 Form PF amendments and broad reporting enhancements
The SEC finalized their most recent set of Form PF amendments in 2024. The SEC, CFTC, and FSOC identified gaps in their information about private fund advisers. The SEC designed the third set of Form PF amendments to address these gaps and enhance regulators’ understanding of the private fund industry and its systemic risks.
Enhanced large hedge fund disclosures
The 2024 amendments expand the scope of large hedge fund adviser reporting to broaden regulator insight into their operations and strategies and improve data quality. The changes impact information, including:
- Investment exposures
- Borrowing and counterparty exposure
- Market factor effects
- Currency exposure
- Turnover
- Country and industry exposure
- Central clearing counterparty reporting
- Risk metrics
- Investment performance
Hedge fund disclosures
- Investment strategies
- Counterparty exposures
- Trading and clearing mechanisms
Additional information for all filing advisers and private funds
The changes require private fund advisers to provide more basic information about themselves and the funds they advise, including:
- Identifying information
- 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
- Fund performance
Critical dates
- Adoption date: February 8, 2024
- Effective date: March 12, 2025
- Initial compliance date: March 12, 2025
Compliance date extensions for 2024 Form PF amendments
Despite the initial March 2025 compliance date, compliance with the broad reporting enhancements adopted in February 2024 remains unenforced after two 2025 compliance deadline extensions:
January 29, 2025: In early 2025, the SEC and CFTC extended the compliance date for the amendments to Form PF adopted in February 2024 from March 12, 2025, to June 12, 2025. The SEC cited the need to “mitigate certain administrative and technological burdens and costs” as the reason for the extension, along with allowing more time for filers to program and test for compliance with the amendments.
June 11, 2025: The day before the newly extended compliance date, the SEC extended the deadline again, this time to October 1, 2025. In a statement, SEC Commissioner Hester M. Peirce reiterated the original administrative reasons for the extension, stating, “the new form is not ready for prime time.”
Commissioner Peirce also said she supported a directive to review Form PF to determine whether the most recently adopted amendments are appropriate or if they represent “unbridled curiosity rather than . . . a legitimate regulatory objective.” The commissioner noted her view that overly extensive reporting requirements are “unduly costly and invasive” and “erroneously suggest that the government’s role with respect to private funds is akin to its role supervising banks, which have a government backstop.”
September 17, 2025: The latest extension indicates the SEC is likely to amend Form PF in the near future. The release noted that “this further extension will provide time to complete a substantive review of Form PF in accordance with a Presidential Memorandum and take any further appropriate actions, which may include proposing new amendments to Form PF.”
Key resources
- SEC Fact Sheet Amendments to Form PF
- SEC/CFTC Final Rule: Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors
- SEC Final Rule: Money Market Fund Reform; Amendments to Form PF (Corrected)
- SEC Press Release: SEC Adopts Amendments to Enhance Private Fund Reporting
- SEC Final Rule: Form PF; Event Reporting for Large Hedge Fund Advisers and Private Equity
- SEC Final Rule: Money Market Fund Reforms; Form PF Reporting Requirements for Large Liquidity Fund Advisers; Technical Amendments to Form N-CSR and Form N-1A
- Fund Advisers; Requirements for Large Private Equity Fund Adviser Reporting
- SEC Press Release: Extension of Form PF Amendments Compliance Date
- SEC Press Release: Further Extension of Form PF Amendments Compliance Date
- SEC Speeches and Statements: Problem Form: Statement on Further Extension of Compliance Date for Form PF
- SEC Speeches and Statements: Extensions on Extensions: Statement on Further Extension of the Form PF Compliance Date
- SEC Speeches and Statements: Statement on Final Joint Amendments to Form PF
- SEC Press Release: SEC and CFTC Extend Form PF Compliance Date to Oct. 1, 2026
