Securities Regulation Daily Wrap Up, INVESTMENT ADVISERS—Agencies extend Form PF compliance date, (Sep 1, 2026)

By Anne Sherry, J.D.

The extension gives the SEC and CFTC time to consider comments on an intervening proposal.

The SEC and CFTC have delayed by nine months the compliance date for 2024 amendments to Form PF. The new compliance date of July 1, 2027, will give the Commissions time to consider comments on their joint proposal to amend and/or eliminate Form PF requirements. Those 2026 amendments would significantly raise the filing threshold, eliminate certain reporting obligations, and streamline other requirements (Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers; Further

Extension of Compliance Date, Investment Advisers Act Release No. 6992 (Aug. 31, 2026)).

As explained in the SEC’s release, Form PF is how certain SEC-registered investment advisers, including those that also are registered with the CFTC as a commodity pool operator or a commodity trading adviser, report confidential information about the private funds that they advise.

Extensions and amendments. On February 8, 2024, the agencies adopted amendments to Form PF with a compliance date of March 12, 2025. That date was extended several times, so entities have not yet had to comply with the new form. Instead, they’ve been using the version of Form PF in effect prior to the 2024 amendments.

On April 20, 2026, the Commissions proposed amendments to Form PF to ease reporting duties and expense for private fund advisers while preserving the form’s purpose in collecting information that aids the Financial Stability Oversight Council in protecting investors from risk. If adopted, the proposal would increase the filing threshold for all filers from $150 million to $1 billion in private fund assets under management. The threshold for being treated as a “large hedge fund adviser” would increase from $1.5 billion to $10 billion in hedge fund assets under management.

Comments on the proposal were due on June 23, 2026. The SEC writes that given the timing of the end of the comment period with the current October 1, 2026 compliance date, and considering the significant impact the 2026 amendments could have on the 2024 amendments, it is appropriate to extend the compliance date out another nine months.

“Commission staff have been carefully reviewing the comments submitted in response to the [2026] amendments, and they are making great progress,” said SEC Chairman Paul Atkins. “However, given the importance of this information collection effort and its technical nature, a short extension is practical and necessary.”

The SEC said that the primary benefit of the delayed compliance date is to allow advisers to avoid the costs of complying with amendments that could be eliminated or modified under the latest proposal. The Commission allows that many advisers may already have incurred a large fraction of the initial costs of compliance, but writes that the delayed compliance date will save incremental compliance costs.

On the other hand, the delayed compliance date will deprive the SEC, CFTC, and FSOC of any economic benefits that would flow from the new information captured by the 2024-amended form. It will also further delay effects on market efficiency, competition, and capital formation. The SEC said that a shorter extension may not have provided enough time for the agencies to consider comments on the 2026 proposal, while a longer extension would delay the accrual of benefits from the 2024 amendments longer than necessary.

This is Investment Advisers Act Release No. 6992.

RegulatoryActivity: CommodityFutures FormsFilings InvestmentAdvisers