Regulatory change has never been a straight line, but lately, the twists are getting sharper and the signposts fewer. The SEC’s recent move on Form PF is a prime example: on June 11, 2025, the SEC turned what was expected to be a simple Form PF deadline extension into a broader discussion on how (and whether) current reporting rules still serve their purpose.
The unsettling reality? While regulators debate the future of risk oversight, compliance deadlines keep ticking - and staying ready costs time, tools, and headspace. The price of uncertainty is high.
In this post, we break down what happened, what it might mean, and how investment firms can respond with confidence, even when the rules are anything but certain.
The SEC met to discuss the compliance timeline for the new Form PF reporting requirements, which had already seen prior delays. A further extension was widely anticipated, and indeed granted. The new compliance date is now set for October 1, 2025.
In a surprising turn, the SEC’s new leadership didn’t just raise concerns about the burden of reporting or the clarity of the rules - they questioned whether Form PF was fit for purpose.
Chairman Paul Atkins called for a full review of the form, stating plainly that he had “serious concerns whether the government’s use of this data justifies the massive burdens that it imposes.” Commissioner Uyeda described the rule as having “run afoul of what good rulemaking looks like.” And in what may be the clearest sign of where this is heading, Commissioner Crenshaw suggested that further compliance extensions would likely follow until the rule was “significantly revised or undone.”
While the form remains in place, the conversation signals a willingness to reconsider how, and how much, information is collected going forward.
The immediate trigger for the delay was a request from the Managed Funds Association (MFA), which argued that the combination of evolving technical specifications, interpretative grey areas, and major data model changes made compliance by the original deadline unworkable.
But reading between the lines, and between the speeches, it’s clear something deeper is going on. The Commissioners’ comments reflected a broader political climate, shaped in part by new Executive Orders directing agencies to revisit recently adopted rules, including in relation to their lawfulness. And perhaps emboldened by that, the SEC’s leadership began asking a question that’s rarely voiced so publicly: do non-banking institutions actually pose systemic risk?
The answer, from several Commissioners, seemed to suggest some doubt.
Which puts Form PF, the regulatory tool designed to monitor exactly that, in an awkward position.
If you’ve been in this space for a while, you’ll know how rare this kind of rhetorical pivot is. For the past decade, systemic risk reporting relating to private markets has been a core part of the post-crisis regulatory consensus, in the US and internationally. Form PF was never perfect, but it served a purpose: giving the Financial Stability Oversight Council (FSOC) visibility into private markets, particularly as they’ve grown in size, complexity, and influence.
The new message coming out of the SEC? That the current approach might need rethinking, though what that actually means in practice remains murky.
It’s a striking position, especially given that:
In that light, it’s not hard to see Form PF as a part of a bigger realignment.
That’s the question. Technically, the revised Form PF is still adopted. But in practice, this extension, and the accompanying commentary, suggest we’re unlikely to see the new requirements enforced any time soon.
And as for the current version of Form PF? A comprehensive review is now underway. We wouldn’t be surprised if revisions are proposed in the coming months, especially as the SEC looks to align its reporting tools with its new regulatory philosophy.
One quote from the meeting sticks in the mind: “We can cabin in systemic risk through the supervision of banks.” That single line offers a telling glimpse into how this SEC may think about systemic risk, and who’s responsible for containing it.
When things get this uncertain, there's a temptation to sit back and wait for clarity. But clarity might not be coming; at least not in the way we’re used to.
Instead, what firms need is a strategy for dealing with regulatory volatility itself. That means building processes that can flex with shifting requirements. It means treating interpretation as a critical skillset. And it means focusing on readiness, not just compliance.
We’re in a moment where rulemaking may be adopted, but not enforced. Deadlines may be set, but not kept. And forms may exist - but only in theory.
So, while no one knows exactly where Form PF is heading, the direction of travel is clear enough: toward more fluid, more contested regulation.
At times like this, our job at FundApps isn’t to predict the future. It’s to prepare you for all of them.
Whether Form PF is reformed, repealed, or quietly rewritten, we’ll keep tracking the signal through the noise, and make sure you have the tools and insight to act when it counts.
Because even when the rules change, compliance still matters. Especially when no one can quite agree on what the rules are.