If you manage private funds with over $150 million in assets, you’ll need to file Form PF—and the requirements are changing significantly in 2025. In this guide, we’re cutting through the complexity and laying out the details you need to know to avoid penalties and stay compliant.
What is Form PF?
Form PF is the U.S. Securities and Exchange Commission (SEC)’s way of keeping tabs on private funds to monitor potential market risks. It’s a detailed disclosure that gives regulators visibility into your fund’s activities without revealing too much to competitors. Born from the 2008 financial crisis, Form PF has grown increasingly important to regulators in the years since, which has also meant increasing complexity for fund managers.
Who needs to file Form PF?
You’re required to file Form PF if you meet the following criteria:
- You’re registered with the SEC as an investment adviser
- You manage one or more private funds (hedge, PE, VC, etc.)
- Your private fund assets total at least $150 million
Many firms mistakenly believe they’re exempt, but the consequences of missing a filing can be severe, including regulatory investigations and reputational damage with investors. If you’re still unsure whether you’re required to file, consult an expert.
What information do you need to provide?
Specifics will vary by fund size and type, but all filers must provide:
- Basic fund structure and investor information
- Assets under management (AUM) by strategy
- Performance data
- Use of leverage and borrowing
Reporting requirements for large funds are more extensive, meaning that large fund advisers typically need two months or more to prepare their first filing under the new requirements.
Critical deadlines to know
The filing deadline is April 30, 2025 for the fiscal year ending on December 31, 2024. The official deadline for the full Form PF expanded requirements has been extended to June 12, 2025.
This timeline creates a perfect storm for many funds, who will need to file under the current rules in April while preparing for the expanded requirements in June.
What’s changing with the Form PF amendments?
Form PF requirements have expanded significantly. Here’s what you need to know before filing in 2025:
More detailed strategy reporting
The updated Form PF requires you to share more portfolio and performance detail than in the past. For many funds, data collection systems will need to be reconfigured to capture and organize information accordingly.
Expanded counterparty disclosures
The SEC now requires more information about your financing relationships and exposures, which again means more data for tracking and reporting.
Portfolio company transparency
Private equity advisers will need to collect additional data from portfolio companies to report on operations and financing.
Better liquidity reporting
Liquidity fund managers must provide more detail about portfolio composition and investor terms, which may require reworking your liquidity monitoring framework.
Challenges teams face with Form PF amendments
Based on our extensive experience supporting Form PF filings, the most common challenges we see our clients facing are:
- Scattered data sources: Form PF data typically lives in multiple systems
- Resource constraints: Compliance teams are already stretched thin
- Calculation complexity: Calculation methods are sometimes ambiguous and difficult to enforce
- Consistency concerns: Consistency across months, quarters, and years is critical
- Time pressure: Large quarterly filers in particular must navigate near-constant reporting deadlines
This is why many leading fund managers choose to outsource Form PF filing rather than increasing pressure on their internal compliance team. Outsourcing is more cost effective, less risky, and more scalable than hiring additional staff.
How IQ-EQ makes Form PF simple
Navigating Form PF requirements can be complex, and compliance with SEC and CFTC requirements is critical. Our expert team ensures your filings are accurate, timely and aligned with updated regulatory standards.
We provide:
- End-to-end support for Form PF preparation and submission
- Regulatory expertise to ensure compliance with evolving SEC and FSOC requirements
- Customized guidance for large fund reporting, tailored to your needs
With deadlines quickly approaching, now is the time to get ahead of your Form PF compliance. Contact our team today.
