Ongoing changes to technical specifications and interpretive guidance leave firms unable to finalize reporting systems
Washington, D.C. — MFA urged the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) to delay the compliance date for the new Form PF by one year, until June 2026, in a letter submitted last Friday. Regulators granted a three-month extension earlier this year, moving the compliance date from March to June 12, 2025.
During the March extension period, FINRA and the SEC have continued to revise the form, modify the XML schema, and issue new interpretive guidance. These ongoing changes have forced advisers and third-party service providers to repeatedly rebuild and re-test systems, undermining efforts to meet the June deadline.
“The March extension was intended to give advisers time to comply with the new form. However, during that period, regulators continued to revise the form, update technical specifications, and issue new guidance,” said Jennifer Han, MFA Chief Legal Officer. “This has required advisers to implement and test complex reporting systems on a moving target. Extending the deadline is necessary to improve data quality, reduce operational risk, and ensure advisers can meet their obligations reliably and lawfully.”
The letter also cites Executive Orders issued by President Donald Trump directing regulators to review recent rulemakings for lawfulness and cost. The amended Form PF exceeds the agencies’ statutory authority and imposes unjustified burdens that do not meaningfully advance systemic risk monitoring. A one-year extension will give regulators time to complete a review and determine whether the rule should be revised or rescinded.
Read the full letter here.
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About the global alternative asset management industry
The global alternative asset management industry — including hedge funds, private credit funds, and hybrid funds — serves thousands of public and private pension funds, charitable endowments, foundations, and other global institutional investors. The industry provides portfolio diversification and risk-adjusted returns to help meet their funding obligations and return targets throughout the economic cycle.
About MFA
Managed Funds Association (MFA), based in Washington, D.C., New York City, Brussels, and London, represents the global alternative asset management industry. MFA’s mission is to advance the ability of alternative asset managers to raise capital, invest it, and generate returns for their beneficiaries. MFA advocates on behalf of its membership and convenes stakeholders to address global regulatory, operational, and business issues. MFA has more than 180 fund manager members, including traditional hedge funds, private credit funds, and hybrid funds, that employ a diverse set of investment strategies. Member firms help pension plans, university endowments, charitable foundations, and other institutional investors diversify their investments, manage risk, and generate attractive returns throughout the economic cycle.
