The clock is ticking on Form PF. The U.S. Securities and Exchange Commission (SEC)’s updated reporting requirements are officially in motion this year, with a firm deadline of June 12, 2025 (extended from March 12). But Form PF for the 2024 fiscal year is still due on April 30, 2025, so now is the time to prepare.
In this article, we’ll cover what’s changing, why it matters, and how to prepare before time runs out.
Key Form PF amendments you need to know
The SEC’s Form PF amendments aren’t just another regulatory checkbox; they represent a fundamental shift in how private funds report to regulators. If you’re managing hedge, private equity or liquidity funds, staying ahead of these changes is critical to your operations and compliance reputation. Read our complete guide for U.S. fund advisers to learn more.
Here are the five amendments most likely to make waves.
#1: More frequent reporting
Previously, the SEC required quarterly reports for gross asset value (GAV) and net asset value (NAV). Now, funds must report these metrics monthly.
Many firms still use GAAP-adjusted GAV balances, which may not mesh well with the SEC’s new expectations. If your fund nets derivatives or cash balances, you may need to update your calculation methods to stay compliant.
#2: Standardized GAV calculation methods
The SEC has flagged inconsistencies in how different funds calculate GAV. Each firm must assess whether their current GAV methodology aligns with the SEC’s approved reporting framework and adjust as needed.
#3: Expanded borrowing and collateral data
Funds must now report borrowing data split by domestic and foreign categories. They will also need to provide more details about collateral and margins. This means more granular tracking, requiring funds to adjust their data gathering and reporting processes.
#4: Mandatory contribution and withdrawal reporting
Fund managers must report detailed figures for investor contributions and withdrawals during each reporting period (similar to requirements under AIFMD in Europe). If your internal systems don’t already have a way to track this data, you may need to refine your workflows to ensure compliance.
#5: New investor tagging categories
There are six new investor classifications funds must use when reporting. Investor relations and compliance teams will need to work together to classify investors correctly and reflect these category updates when they file.
How to prepare for the new Form PF requirements
Most firms underestimate the time required to implement regulatory changes, leaving them scrambling when deadlines draw closer.
Here’s how to get ahead:
- Review your reporting framework: Assess whether your current Form PF processes meet the updated requirements from the SEC
- Improve data collection practices: Make sure you can accurately track and report on metrics like counterparty risk and fund financing
- Strengthen internal teams: Work with your legal, finance and compliance teams to audit your reporting processes and plug any gaps
- Plan for system updates: Capturing new data often requires coordination between multiple teams and vendors, so don’t wait to get started
- Allocate resources wisely: Decide whether you’ll handle compliance in-house or bring in external support
How IQ-EQ can help
Our Form PF specialists handle the entire filing process, freeing your team to focus while we ensure compliance and mitigate risk. We help private fund advisers:
- Prepare and submit Form PF filings, accurately and on time
- Align reporting processes with new SEC requirements
- Ensure investor classification, borrowing disclosures and liquidity metrics are reported properly
With deadlines quickly approaching, now is the time to get ahead of your Form PF compliance. Contact our team today.
