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Client Alert

SEC and CFTC Further Extend Compliance Date for the 2024 Form PF Amendments

September 3, 2026

The Commissions extend the compliance deadline by an additional nine months to consider comments to the 2026 Proposal to scale back Form PF reporting.

On August 31, 2026, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC, and together with the SEC, the Commissions) adopted a joint final rule extending the compliance date for the amendments to Form PF adopted on February 8, 2024 (the 2024 Amendments) from October 1, 2026 (the Prior Compliance Date) to July 1, 2027 (the New Compliance Date). Extending the compliance date for the 2024 Amendments allows Form PF filers to avoid certain potentially significant costs associated with implementing provisions of the 2024 Amendments that the Commissions have subsequently proposed to amend and/or eliminate in a new rule proposal issued on April 20, 2026 (the 2026 Proposal).

Background

Form PF requires certain SEC-registered investment advisers to private funds (including those that are also CFTC-registered commodity pool operators or commodity trading advisers) to confidentially disclose information to the Commissions regarding the funds they advise.

The 2026 Proposal, if adopted as proposed, would modify or replace certain changes made by the 2024 Amendments, including by raising the filing threshold, eliminating certain reporting obligations, and streamlining other reporting requirements.

The Commissions are currently considering comments on the 2026 Proposal. Given the timing of the Prior Compliance Date and the end of the comment period, as well as the significant impact that the 2026 Proposal could have on the 2024 Amendments if adopted as proposed, the Commissions determined to set the New Compliance Date.

The Commissions stated that the extension would prevent compliance costs for Form PF filers this year that would not be in line with the 2026 Proposal once implemented, and it also gives the Commissions time to consider comments om the 2026 Proposal. In addition, the New Compliance Date is intended to provide filers with sufficient time to comply with the 2024 Amendments in the event the Commissions do not adopt the 2026 Proposal in whole or in part.

For additional information regarding the 2026 Proposal, please see this Latham Client Alert.

Endnotes

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