The Securities and Exchange Commission (SEC) on Wednesday voted 3-1 to delay a compliance deadline for new Form PF filing requirements until Oct. 1.  The rule aimed to expand the amount of trading data private fund advisors give the regulator.

The commission, alongside the Commodity Futures Trading Commission (CFTC), adopted the new disclosure requirements in February 2024 under former SEC Chairman Gary Gensler, and they had been set to go into effect on Thursday, after the regulator agreed to a three-month delay earlier this year. The CFTC is expected to consider whether to delay the rule later today.

Priorities for Investment Managers

Investment managers required to file Form PF on a quarterly basis should still develop a strategy for implementing and adopting the new Form PF with their advisors and technology providers.  While much of the substantive information in the filing remains the same, the SEC has changed several definitions and increased the types of information required.  These changes will require technology teams to work with front and middle office experts to interpret the changes and update stored logic for populating the data tables used in responding to the Form PF.

Our clients have begun adopting the changes to Form PF and are working on enriching data and modifying their calculations to ensure they are ready once the new Form PF becomes effective.  For more information on the changes to Form PF or to speak with a Form PF expert, please contact Brandon Caroprese at bcaroprese@caroprese.com.