CFTC and SEC push Form PF compliance deadline to July 1, 2027

The Commodity Futures Trading Commission and the Securities and Exchange Commission have jointly extended the compliance date for the 2024 Form PF amendments from October 1, 2026, to July 1, 2027. The rule becomes effective on September 3, 2026, and applies to all SEC-registered investment advisers that report private-fund data on Form PF, including advisers also registered with the CFTC as commodity pool operators or commodity trading advisers.

The agencies originally set a single compliance date of March 12, 2025, when the amendments were adopted on February 8, 2024 (Release No. IA-6546, 89 FR 17984). Subsequent extensions moved the deadline to June 12, 2025 (Release No. IA-6838, 90 FR 9007), then to October 1, 2025 (Release No. IA-6883, 90 FR 25140), and most recently to October 1, 2026 (Release No. IA-6919, 90 FR 45131). Filers have been permitted to continue filing the pre-amendment version of Form PF until each successive deadline.

The latest extension is tied to the comment period for the 2026 Proposed Form PF Amendments, which closes on June 23, 2026. The commissions stated that an additional nine-month delay will give filers time to avoid potentially significant costs associated with the 2024 amendments while the agencies evaluate the proposed 2026 changes and decide whether further action is warranted.

Advisers should continue using the current Form PF until the July 1, 2027 deadline, unless the proposed 2026 amendments are adopted and become effective earlier. For questions, the SEC listed senior counsel Alexis Palascak, Janet Jun, and Daniel Levine, among others, and the CFTC listed Special Counsel Michael Ehrstein as contacts.

The final rule is published under FR Doc No. 2026-18104, with RINs 3038-AF31 (CFTC) and 3235-AN13 (SEC).