An SEC-registered adviser to private funds with at least $150 million in private fund assets at its last fiscal year end files Form PF. Most file once a year, within 120 calendar days of their fiscal year end. Large hedge fund advisers file quarterly within 60 days of each calendar quarter end, and large liquidity fund advisers within 15 days.
Check the date against your own records.
Deadlines by type of adviser
- Most private fund advisers: an annual update within 120 calendar days of the fiscal year end
- Large hedge fund advisers: a quarterly update within 60 calendar days of each calendar quarter end
- Large liquidity fund advisers: a quarterly update within 15 calendar days of each calendar quarter end
- Private equity fund advisers: event reports in Section 6 within 60 calendar days of the end of the fiscal quarter in which the event happened
Filing
Form PF is filed electronically through the Private Fund Reporting Depository (PFRD) on IARD, with a filing fee. It counts as filed only when the system accepts it, which it won't until the fee is paid (17 CFR 275.204(b)-1).
Changes to the form
The SEC and CFTC adopted amendments to Form PF in 2024 and have pushed their compliance date back several times. Check the SEC's Form PF page for the current date before your next filing.
Also on the calendar
If you rely on the custody rule's audit approach, the audited fund financial statements go to investors within 120 days of each fund's fiscal year end too, and the Form ADV annual amendment is due within 90 days.
Get reminded before it's due
Regmindr tracks this alongside the rest of your compliance calendar, and emails your team before each deadline. Set it up from your year end in about two minutes.
Sources
- 17 CFR 275.204(b)-1: Reporting by investment advisers to private funds
- SEC: Form PF and instructions
- SEC: Form PF compliance date extended to October 1, 2026
This page is a summary, not legal or regulatory advice. The rules in the sources above take precedence.