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ARTICLE · 19 SEPTEMBER 2025

SEC Again Extends Compliance Deadline For Form PF Amendments To October 1, 2026

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On September 17, 2025, the Securities and Exchange Commission for a third time extended the compliance date for the Form PF amendments originally adopted on February 8, 2024 until October 1, 2026.

United StatesStrategy
Jason M. Daniel
Jason M. Daniel
Barbara Niederkofler
Barbara Niederkofler
William K. Wetmore
William K. Wetmore
Brian P. Rafferty
Brian P. Rafferty
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On September 17, 2025, the Securities and Exchange Commission for a third time extended the compliance date for the Form PF amendments originally adopted on February 8, 2024 until October 1, 2026. In the interim, the SEC staff will reconsider the thresholds for registered investment advisers to be required to report on Form PF and the scope of the information that it collects.

As the new compliance date will be after April 30, 2026 – the annual Form PF amendment deadline for filing advisers whose fiscal year matches the calendar year—the effective compliance date for many annual Form PF filers will now be 2027. Quarterly filers, such as large hedge fund advisers, will need to be compliant with the amended (or further amended) Form PF obligations for filings relating to the third quarter of 2026. We anticipate that many registered investment advisers will likely delay updating their internal data collection processes to address the 2024 amendments until Form PF is

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