Decoding the SEC’s Latest Form PF Amendments: What You Need to Know Before the March 2025 Deadline


Jordan Dague
Product Manager, Confluence
The SEC’s latest changes to Form PF are here, and they’re shaking things up in a major way for US private fund advisors. Forget business as usual—these changes require a holistic review of existing reporting methodologies and processes. This represents a significant challenge for private fund advisors and their service providers, but it can also serve as an opportunity to take a strategic view of Form PF reporting operations and how they can be enhanced for the long term.

In SEC’s third and most substantial set of changes to Form PF in under 12 months, Sections 1 and 2 are given a major makeover, and with a March 2025 compliance deadline, Form PF filers need to move quickly to respond.

So, why the big change? The SEC, CFTC, and Financial Stability Oversight Council (FSOC) want a clearer picture of the systemic risk associated with private funds’ activity in markets. In working with the data submitted on Form PF over the course of the form’s first decade, FSOC has identified areas where the existing form results in blind spots or ambiguity, and the recently adopted changes are aimed at addressing those shortfalls.

In this post, we take a closer look at the adopted Form PF revisions, dig into the challenges that they represent, and consider how Form PF filers can start to prepare for the fast-approaching compliance date.

Overview of the Form PF Amendments

While the adopted Final Rule makes at least small adjustments to virtually all parts of Form PF and impacts all filers (we identified over 50 distinct changes across Sections 1 and 2!), the changes are particularly impactful for large hedge fund advisors. Focusing in on this group of filers, there are a few areas where the changes pose a particularly potent compliance challenge:

  1. Changes to Fund Structure Reporting
    One of the significant changes involves how funds report their structures, particularly concerning master-feeder and parallel fund arrangements. Previously, firms could report master-feeder and parallel fund structures in aggregate, but the new requirements mandate separate reporting of these entities. Feeder funds investing only in the master fund, cash, cash equivalents, and U.S. Treasuries can be disregarded from reporting, providing a bit of respite. But, on the other hand, filers will now have to submit a separate Section 2 for feeders to hedge funds that don’t meet the requirements to be disregarded and that have over $500 million in net assets—a major new burden.
  2. More Detailed Investment Exposure Reporting for Qualifying Hedge Funds
    For Qualifying Hedge Funds (those with over $500 million in net assets), the amendments also introduce more granular reporting requirements for investment types and asset classes. First, the asset type exposure breakout has been restructured, with an increased focus on reference assets: in calculating gross exposures, each investment in a fund’s portfolio must be classified by the asset class of the underlying security and filers must now also identify the instrument type of each investment, specifying whether the exposure to the underlying security is achieved directly, synthetically in a derivative transaction, or indirectly through investment in a fund. Additionally, a new adjusted exposure breakout requires funds to net offsetting positions in the same reference asset across instrument types, and large concentrations in a single reference asset must be reported on a security-by-security basis.
  3. More Detailed Counterparty Exposure Reporting for All Hedge Funds
    The updated Sections 1 and 2 also introduce new consolidated counterparty exposure tables. On one hand, these tables simplify reporting by bringing previously disparate questions about borrowings, counterparty credit exposure, and margin/collateral into a single central location. On the other hand, the level of detail that must be reported is increased. This is especially true for Qualifying Hedge Funds, which must complete a separate consolidated counterparty exposure table for each of a fund’s five largest debtor and creditor counterparties.
  4. New Look-through Requirements
    New look-through requirements bring an additional dimension of complexity to the updated investment and counterparty exposure questions. Filers will now be required to look through trading vehicles (defined as legal entities that hold assets, incur leverage, or conduct trading on behalf of a fund but do not operate a business), meaning that all underlying investment and counterparty exposure obtained through such vehicles must be reported as if the activity is in the fund itself. For large counterparty exposures, filers will have to separate direct exposures and those obtained through trading vehicles by identifying the exposed entity. In addition, Qualifying Hedge Funds will be expected to look through investments in other funds, including unaffiliated funds, and at least estimate asset class exposure based on the investee fund’s asset allocation.

Challenges Ahead: Move Swiftly, But Don’t Panic

While these changes may seem overwhelming, there’s still time to get ready. Here’s what you need to know to get started:

  • Data Source SOS The increased granularity in reporting requirements will demand enhanced data sourcing capabilities. You’ll likely need to upgrade your data gathering systems to handle the amplified reporting detail. You may also need to invest in technology and processes that can handle the required detailed data collection and reporting. Think of it as an investment in future-proofing your compliance.
  • Time is Ticking The deadline for these new rules is March 2025, presenting firms with a tight timeline to adjust their reporting processes. Don’t wait until the last minute—start reviewing your current practices now and get ready to adapt. This short window is a challenge, especially when coupled with other competing compliance requirements in the industry.
  • Operational Transformation Be prepared to adjust your internal operations to meet the new requirements. Technology upgrades, staff training, and potential restructuring might be on the horizon. Evaluate your current operations and make necessary adjustments to meet the new mandates. Operational transformation involves not only technological upgrades, but also training and possibly restructuring within your organization to handle the new reporting demands effectively.
  • Preparing for the Changes The SEC’s amendments to Form PF reflect a continued push towards greater transparency and risk management in the private fund space, bringing about significant challenges for firms. Funds must now focus on upgrading their reporting and data management systems to comply with these new requirements, ensuring they remain compliant and competitive in a rapidly evolving regulatory landscape—all within a tight timeline.

    What’s the best path forward? Begin preparations immediately by conducting impact analyses specific to your operations and structures. Then, establish robust data management processes and engage with technology providers to ensure your systems can handle the new reporting requirements.

Ready to tackle these new Form PF requirements?

Confluence is here to help. Our team of experts can guide you through the process and ensure your reporting is on point.

About Confluence

Confluence is a leading global technology solutions provider committed to helping the investment management industry solve complex data challenges across the front, middle and back office. From data-driven portfolio analytics to compliance and regulatory solutions, including investment insights and research, Confluence invests in the latest technology to meet the evolving needs of asset managers, asset owners, asset services and asset allocators to provide best-of-breed solutions that deliver maximum scalability, speed and flexibility, while reducing risk and increasing efficiency. Headquartered in Pittsburgh, PA, with 900+ employees in 15 offices spanning across the United Kingdom, Europe, North America, South Africa, and Australia, Confluence services over 1000 clients in more than 40 countries. For more information, visit

Confluence Media Contact:

Vanja Lakic
[email protected]
+1 (917) 660-8527