Thank you, Mr. Chairman and Natasha [Greiner] and Oliver [Richard]. I support extending the compliance date for the February 8, 2024 amendments to Form PF[1] to October 1, 2025.[2] Extending the compliance date until then will give filers and their third-party service providers additional time to develop and test their reporting systems. As the request letter noted, “private fund advisers subject to the rule [need] additional time to build and test the new reporting systems and work through any outstanding reporting and interpretive questions with the goal of providing uniform data to the Commissions.”[3] The new form is not ready for prime time. The extension reflects a commitment to good governance and common-sense implementation.
Although I support an extension, my concerns about Form PF and its recent expansions persist. We should reassess whether the information the form collects aligns with the intended purpose of the form. As I noted in my dissent to the adoption of the amendments we are extending, “unbridled curiosity rather than . . . a legitimate regulatory objective”[4] shapes the demands of Form PF. Overly extensive reporting requirements not only are unduly costly and invasive, but erroneously suggest that the government’s role with respect to private funds is akin to its role supervising banks, which have a government backstop. I support the Chairman’s directive to review Form PF to determine whether it serves its intended systemic risk mitigation purpose.
I want to thank the Commodity Futures Trading Commission and SEC staff in the Divisions of Investment Management and Economic and Risk Analysis and Office of General Counsel for their quick work in drafting the extension release. Let me close with a word of thanks to Natasha Greiner, who has served the Commission so well for almost a quarter of a century, culminating with her role as Director of the Division of Investment Management.[5] Thank you, Natasha, and we wish you the best as you leave the agency. Your willingness to pitch in and help wherever you could will continue to serve as a model for the rest of us. You will be missed.
[1] Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers, Release No. IA-6546, (Feb. 8, 2024) [89 FR 17984 (Mar. 12, 2024) (codified at 17 C.F.R. pt. 279)], https://www.govinfo.gov/content/pkg/FR-2024-03-12/pdf/2024-03473.pdf.
[2] The original compliance date for the Form PF amendments was March 12, 2025. Id. at 18031. On January 29, 2025, the Commission extended the compliance date to June 12, 2025. Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers; Extension of Compliance Date, Release No. IA-6838 (Jan. 29, 2025) [90 FR 9007 (Feb. 5, 2025) (codified at 17 C.F.R. pt. 279)], https://www.govinfo.gov/content/pkg/FR-2025-02-05/pdf/2025-02138.pdf.
[3] Managed Funds Association, Comment Letter re: Request for Further Extension of the Compliance Date of the Amended Form PF Reporting Requirements 5 (May 23, 2025), https://www.mfaalts.org/wp-content/uploads/2025/05/MFA-Letter-to-SEC-and-CFTC-re.-Form-PF-Extension-Request-As-submitted-5.23.25.pdf. Among other things, the letter noted that since the last extension, the Financial Industry Regulatory Authority (“FINRA”) has further developed the XML reporting schema for the amended Form PF and continues to make changes to the completeness checks file and validations being performed in the FINRA test portal. Id. at 2–3.
[4] Commissioner Hester M. Peirce, Curiouser and Curiouser: Statement on Amendments to Form PF to Amend Reporting Requirements for All Filers and Large Hedge Fund Advisers (Feb. 8, 2024), https://www.sec.gov/newsroom/speeches-statements/peirce-statement-amendments-form-pf-amend-reporting-reqs-020823.
[5] U.S. Securities and Exchange Commission, Press Release No. 2025-84, Natasha Vij Greiner Will Conclude Her Tenure as Director of Investment Management (June 10, 2025), https://www.sec.gov/newsroom/press-releases/2025-84-natasha-vij-greiner-will-conclude-her-tenure-director-investment-management.
