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Alternative Market Briefing

Other Voices: SEC and CFTC further extend compliance date for Form PF amendments

Monday, September 29, 2025

By: Leslie Cruz, Jodi Erlandsen, Adam Kanter, Peter McCamman - Mayer Brown

On September 17, 2025, the Securities and Exchange Commission and the Commodity Futures Trading Commission jointly granted a further one-year extension to the compliance date for amendments to Form PF that were originally adopted by both Commissions on February 8, 2024.

The compliance date for the Form PF Amendments was extended from October 1, 2025 to October 1, 2026. Form PF is the form that certain SEC-registered investment advisers use to report confidential information about the private funds that they advise. According to their joint release, the SEC and CFTC granted the extension after noting the additional one-year extension would provide further time for the SEC and CFTC to complete a substantive review of the Form PF Amendments in accordance with a January 20, 2025 Presidential Memorandum from President Donald Trump, which directed agencies to consider delaying or postponing the effective date of rules not yet in effect for the purpose of reviewing any questions of fact, law, and policy that such rules may raise. As part of that review, the Joint Release indicated that the SEC and CFTC might consider taking further appropriate actions, which may include proposing new amendments to Form PF, and that the review would also continue to consider the costs and benefits of the Form PF Amendments.

If no further amendments to Form PF were determined to be needed after the review is complet......................

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