United States: STOP! START AGAIN! JUST KIDDING, STOP AGAIN! SEC Provides 11th Hour Extension of Compliance Date for Amended Form PF

By: Pablo J. Man and Ruth E. Delaney

With less than a day to go before the 12 June 2025 compliance date for the SEC and CFTC’s jointly adopted amendments to Form PF, the SEC, together with the CFTC, voted today to further extend the compliance date for the amended form to 1 October 2025.

Citing concerns regarding “gobbledygook” within the form instructions, among other difficulties raised by impacted filers, Chairman Atkins indicated that the further extension would provide filers and the staff with additional time to work through issues with the amended form.

In addition to the extension, in a hint of possible further SEC actions ahead, Chairman Atkins also indicated that he has directed the staff to undertake a “comprehensive review” of Form PF in its entirety to confirm that the data collected is consistent with the form’s stated purpose of permitting agencies to monitor systemic risk.