Key Takeaways From the Latest Round of Form PF Amendments (Part Two of Two)

Among the many rulemakings that have come out of the SEC in the last few years are several targeting Form PF, including the most recent amendments (Amendments) from both the SEC and CFTC. The granular reporting on large hedge funds that will be required by the Amendments, together with the increased reporting under previous Form PF amendments, will further increase the burden on private fund managers and their compliance staffs. The Amendments and the adopting release were published in the Federal Register on March 12, 2024, and will take effect on March 12, 2025. This second article in our two-part series provides key takeaways from the Amendments and next steps for hedge fund managers. The first article outlined the specific provisions and requirements set forth in the Amendments. See our two-part series on the originally proposed amendments to Form PF: “Overview and Goals” (Sep. 15, 2022); and “Rationale, Commissioner Views and Need for Comments” (Sep. 22, 2022).

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