IAA Supports Form PF Compliance Date Extension

June 10, 2025

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The Honorable Paul S. Atkins
Chairman
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Re: Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (SEC Rel. No. IA-6546)

Dear Chairman Atkins:

The Investment Adviser Association (IAA)[1] appreciates that the SEC has noticed an open meeting for June 11, 2025, to consider the February 2024 Form PF amendments compliance date.[2] We write to express our strong support for an extension of the compliance date beyond June 12, 2025. As we have noted previously,[3] implementing the new Form PF amendments has created significant compliance and technological challenges for private fund advisers.

We commend the SEC for issuing a three-month extension of the Form PF compliance date in January.[4] Unfortunately, in part because the XML reporting scheme for new Form PF was only finalized as of May 2, 2025, we believe that additional time is still needed to source and integrate the new data reporting requirements, refine workstreams, and ensure accurate filings.

For example, many large hedge fund advisers that are scheduled to report by August 29, 2025, are relying on third-party vendors that are continuing to develop new reporting solutions under the recently released technical specifications. Advisers need to work with vendors to test the data and ensure accurate reporting. An extension will provide much-needed time for these advisers to continue to operationalize the new requirements.

Accordingly, we urge the Commission to further extend the Form PF compliance date to allow all advisers to incorporate the newly released technical requirements. While we requested an additional three-month extension, to September 12, 2025, we strongly support a longer extension to address the concerns that have also been raised by others.

In addition, while recent SEC staff FAQs address some interpretive concerns, critical questions about the broad scope of some definitions and data requests remain unresolved. For example, private equity fund advisers are required to report on potentially hundreds of indirectly related legal entities under the new “trading vehicle” definition, which in our view will not provide relevant information to the Commission. We believe the SEC should narrow the scope of the definition, which would reduce the significant burden on these advisers without impacting the SEC’s ability to receive meaningful information, and we look forward to working with the staff on this and other challenges that private equity fund advisers face.

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Thank you for your consideration of our comments. We’d be happy to provide any additional information. Please do not hesitate to contact the undersigned at (202) 293-4222 if we can be of further assistance.

Respectfully Submitted,

Gail C. Bernstein
General Counsel and Head of Public Policy

Monique S. Botkin
Associate General Counsel

cc:
The Honorable Mark T. Uyeda, Commissioner
The Honorable Hester M. Peirce, Commissioner
The Honorable Caroline A. Crenshaw, Commissioner
Natasha Vij Greiner, Director, Division of Investment Management

The Honorable Caroline D. Pham, Acting Chairman, CFTC
The Honorable Kristin N. Johnson, Commissioner, CFTC

[1] The IAA is the leading organization dedicated to advancing the interests of fiduciary investment advisers. For more than 85 years, the IAA has been advocating for advisers before Congress and U.S. and global regulators, promoting best practices and providing education and resources to empower advisers to effectively serve their clients, the capital markets, and the U.S. economy. Our members range from global asset managers to the medium- and small-sized firms that make up the majority of our industry. Together, the IAA’s member firms manage more than $35 trillion in assets for a wide variety of individual and institutional clients, including pension plans, trusts, mutual funds, private funds, endowments, foundations, and corporations. For more information, please visit www.investmentadviser.org.

[2] SEC Open Meeting Notice (June 4, 2025).

[3] We requested additional time in our May 1 letter welcoming you to the Commission and outlining the IAA’s priorities, as well as in an earlier letter to then-Acting Chairman Uyeda. We also joined other trade associations in a request for an extension in late 2024. See IAA Letter to Chairman Atkins (May 1, 2025), IAA Letter to Acting Chairman Mark T. Uyeda (Jan. 29, 2025), and IAA and Trades Request Extension of Compliance Date for Form PF Amendments (Dec. 13, 2024).

[4] See SEC and CFTC, Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers; Extension of Compliance Date, SEC Rel. No. IA-6838 (Jan. 29, 2025).