What happened: The SEC released updated Staff frequently asked questions (FAQs) on new Form PF, which goes into effect on March 12, 2025. The FAQs were published Friday and do not address the operational concerns that MFA has been raising.
Why it matters: The amendments to Form PF impose new disclosure requirements on alternative asset managers and were jointly adopted by the SEC and CFTC this February. The rushed implementation timeline creates significant compliance challenges for managers and many interpretive questions remain unanswered. The FAQs signal the current Commission’s interest in proceeding with the established timeframes by ignoring the operational challenges and addressing questions relating to instructions and other interpretive matters.
MFA on the issue: MFA requested the SEC and CFTC extend the compliance deadline for the amended Form PF requirements by six months in a letter with other trade associations earlier this year. MFA has met and will continue to meet with commissioners and their staff. Leading up to and after our extension request, MFA has had weekly meetings with the SEC staff to report and discuss the technological and operational issues relating to the Form PF XML schema.
What’s next: MFA will continue to work with the SEC and its staff to get an extension of the March 12 compliance deadline and address any remaining interpretive questions.
