On August 31, 2026, the SEC and the CFTC voted to extend the compliance date for amendments to Form PF for a fourth time, resulting in a new compliance date of July 1, 2027. Form PF is the confidential reporting form filed by certain SEC-registered private fund investment advisers, including those that also are registered with the CFTC as commodity pool operators or commodity trading advisers, to report confidential information about the private funds that they advise. The amendments to Form PF were adopted on February 8, 2024 with an original compliance date set for March 12, 2025.
On January 29, 2025, the SEC and the CFTC extended the compliance date of the Form PF amendments to June 12, 2025 in order to address certain challenges associated with the timing of reporting cycles for Form PF. On June 11, 2025, they further extended the compliance date to October 1, 2025 in order to provide more time for filers to develop and test their Form PF reporting systems, and on September 17, 2025, they again extended the compliance date to October 1, 2026 to allow the agencies more time to complete a substantive review of Form PF in accordance with the January 20, 2025 Presidential Memorandum directing agencies to consider postponing the effective date of any rules that had been published in the Federal Register, or that were issued but had not yet taken effect, for the purpose of reviewing any questions of fact, law, and policy that the rules may raise.
Following that third extension of the compliance date, in April 2026, the SEC and the CFTC jointly proposed amendments that would significantly narrow the scope of Form PF. The proposal is intended to reduce recent expansions that result in overly burdensome reporting requirements and would partially unwind the Biden administration’s 2024 Form PF amendments.
In this most recent extension of the compliance date for the February 2024 amendments to Form PF, resulting in a new compliance date of July 1, 2027, the SEC and CFTC noted the potentially significant impact of the more recent April 2026 proposed amendments to Form PF, which have not yet been finalized and with respect to which the agencies are considering comments received. The agencies stated that the additional compliance date extension is necessary to allow Form PF filers to avoid certain potentially significant costs associated with aspects of the 2024 Form PF amendments that have been proposed to be amended or eliminated. As a result, filers may continue to use the current version of Form PF until July 1, 2027.
The joint final rule extending the compliance date is available here.
