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COMMODITY FUTURES TRADING COMMISSION

17 CFR Chapter I

RIN 3038-AF31

SECURITIES AND EXCHANGE COMMISSION

17 CFR Part 279

Release No. IA-6992; File No. S7-22-22

RIN 3235-AN13

Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers; Further

Extension of Compliance Date

AGENCIES: Commodity Futures Trading Commission and Securities and Exchange

Commission.

ACTION: Joint final rule; further extension of compliance date.

SUMMARY: The Commodity Futures Trading Commission (the “CFTC”) and the Securities

and Exchange Commission (the “SEC”) (collectively, “we” or the “Commissions”) are further

extending the compliance date for the amendments to Form PF that were adopted on February 8,

2024, from October 1, 2026, to July 1, 2027. Form PF is the confidential reporting form for

certain SEC-registered investment advisers to private funds, including those that also are

registered with the CFTC as a commodity pool operator (a “CPO”) or a commodity trading

adviser (a “CTA”).

DATES: Effective date: The effective date for this release is September 3, 2026. Compliance

date: As of September 19, 2025, the compliance date for the amendments to Form PF codified

March 12, 2024, at 89 FR 17984, and delayed February 5, 2025, at 90 FR 9007, further delayed

June 16, 2025, at 90 FR 25140, and further delayed October 1, 2026, at 90 FR 45131, is further

delayed until July 1, 2027.

FOR FURTHER INFORMATION CONTACT: SEC: Alexis Palascak, Janet Jun, and Daniel

Levine, Senior Counsels; Samuel Thomas, Branch Chief; Adele Kittredge Murray, Private Funds

Attorney Fellow; or Robert Holowka, Assistant Director, Investment Adviser Regulation Office,

at (202) 551-6787, Division of Investment Management, Securities and Exchange Commission,

100 F Street NE, Washington, DC 20549-8549. CFTC: Michael Ehrstein, Special Counsel, at

(202) 418-6700, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st

Street NW, Washington, DC 20581.

SUPPLEMENTARY INFORMATION: The Commissions are extending the compliance date

of the 2024 Form PF Amendments under the Investment Advisers Act of 1940 (the “Advisers

Act”). 1

Agency

Reference

CFR Citation

CFTC & SEC

Form PF 2

17 CFR 279.9

15 U.S.C. 80b. Unless otherwise noted, when we refer to the Advisers Act, or any section of the Advisers

Act, we are referring to 15 U.S.C. 80b, in which the Advisers Act is codified, and when we refer to rules

under the Advisers Act, or any section of these rules, we are referring to title 17, part 275 of the Code of

Federal Regulations [17 CFR 275], in which these rules are published.

Congress enacted Sections 404 and 406 of the Dodd-Frank Wall Street Reform and Consumer Protection

Act of 2010 (the “Dodd-Frank Act”), which require that private fund advisers file reports and specify

certain types of information that should be subject to reporting and/or recordkeeping requirements. Pub. L.

111-203, 124 Stat. 1376 (2010). With respect to such reports, the Dodd-Frank Act authorizes the SEC to

require that private fund advisers file such information “as necessary and appropriate in the public interest

and for the protection of investors, or for the assessment of systemic risk.” The result of this enactment is

Form PF, which is a joint form between the SEC and CFTC only with respect to sections 1 and 2 of the

Form.

DISCUSSION

On February 8, 2024, the Commissions adopted amendments to Form PF 17 CFR 279.9

under the Advisers Act (the “2024 Form PF Amendments”). 3 Form PF is the form that certain

SEC-registered investment advisers, including those that also are registered with the CFTC as a

CPO or a CTA, use to report confidential information about the private funds 4 that they advise.

The Commissions initially established a single effective and compliance date for the 2024

Form PF Amendments of March 12, 2025, which was one year from its date of publication in the

Federal Register (the “Initial Compliance Date”). On January 29, 2025, the Commissions

extended the compliance date of the 2024 Form PF Amendments to June 12, 2025, to address

certain challenges associated with the timing of reporting cycles for Form PF. 5 Subsequently, the

Commissions became aware of remaining significant challenges associated with coming into

compliance with the 2024 Form PF Amendments by June 12, 2025, and further extended the

Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers, Release No. IA-6546

(Feb. 8, 2024) [89 FR 17984 (Mar. 12, 2024)] (“2024 Adopting Release”). Any reference to the

“Commissions” or “we,” as it relates to the collection and use of Form PF data, are meant to refer to the

agencies in their separate or collective capacities (as the context requires or permits), and such data from

filings made pursuant to 17 CFR 275.204(b)-1, by and through Private Fund Reporting Depository, a

subsystem of the Investment Adviser Registration Depository, and reports, analysis, and memoranda

produced pursuant thereto.

See 17 CFR 275.204(b)-1. Advisers Act section 202(a)(29) defines the term “private fund” as an issuer that

would be an investment company, as defined in section 3 of the Investment Company Act of 1940 (the

“Investment Company Act”), but for section 3(c)(1) or section 3(c)(7) of that act. Section 3(c)(1) of the

Investment Company Act provides an exclusion from the definition of “investment company” for any

issuer whose outstanding securities (other than short-term paper) are beneficially owned by not more than

one hundred persons (or, in the case of a qualifying venture capital fund, 250 persons) and which is not

making and does not presently propose to make a public offering of its securities. Section 3(c)(7) of the

Investment Company Act provides an exclusion from the definition of “investment company” for any

issuer, the outstanding securities of which are owned exclusively by persons who, at the time of acquisition

of such securities, are qualified purchasers (as defined in section 2(a)(51) of the Investment Company Act),

and which is not making and does not at that time propose to make a public offering of such securities.

Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers; Extension of

Compliance Date, Release No. IA-6838 (Jan. 29, 2025) [90 FR 9007 (Feb. 5, 2025)] (“Initial Compliance

Date Extension Release”).

compliance date to October 1, 2025. 6 The Commissions extended the compliance date again to

October 1, 2026, (the “Current Compliance Date”) to allow for more time to complete a

substantive review of Form PF and determine whether to take any further appropriate actions. 7

Accordingly, filers have been allowed to file the version of Form PF in effect prior to the 2024

Form PF Amendments (the “Current Form PF”) until the Current Compliance Date.

Following the Current Compliance Date extension, the Commissions proposed additional

amendments to Form PF to reduce private fund reporting burdens while ensuring the continued

collection of necessary and appropriate information. 8 The proposed additional amendments, if

adopted, would significantly raise the filing threshold, eliminate certain reporting obligations,

streamline other requirements, and make corrections and other revisions. The Commissions are

currently considering comments on the 2026 Proposed Form PF Amendments, which were

requested to be submitted on or before June 23, 2026. Given the timing of the Current

Compliance Date and the end of the comment period for the 2026 Proposed Form PF

Amendments, as well as the significant impact that these proposed amendments could have with

respect to the 2024 Form PF Amendments if adopted as proposed, we are further extending the

compliance date for the 2024 Form PF Amendments to July 1, 2027. Extending the compliance

date for the 2024 Form PF Amendments by an additional 9 months is needed to allow Form PF

filers to avoid certain potentially significant costs associated with aspects of the 2024 Form PF

Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers; Further Extension of

Compliance Date, Release No. IA-6883 (June 11, 2025) [90 FR 25140 (June 16, 2025)].

Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers; Further Extension of

Compliance Date, Release No. IA-6919 (Sept. 17, 2025) [90 FR 45131 (Sept. 19, 2025)].

See Form PF; Reporting Requirements for All Filers, Release No. IA-6959 (Apr. 20, 2026) [91 FR 22232

(Apr. 24, 2026)] (“2026 Proposed Form PF Amendments”).

Amendments that the Commissions have proposed to amend and/or eliminate, while the

Commissions consider comments on the Proposed 2026 Form PF Amendments and whether to

take further action. In addition, the compliance date extension is intended to provide Form PF

filers with sufficient time to comply with the 2024 Form PF Amendments in the event the

Commissions do not adopt the proposed amendments in whole or in part.

II.

ECONOMIC ANALYSIS

The SEC is mindful of the economic effects, including the costs and benefits, of the

compliance date extension. Section 202(c) of the Advisers Act provides that when the SEC is

engaging in rulemaking under the Advisers Act and is required to consider or determine whether

an action is necessary or appropriate in the public interest, the SEC shall also consider whether

the action will promote efficiency, competition, and capital formation, in addition to the

protection of investors.

The baseline against which the costs, benefits, and the effects on efficiency, competition,

and capital formation of the compliance date extension are measured consists of the current state

of the market, Form PF filers’ current practices, and the current regulatory framework, including

recently adopted rules. The changes to Form PF in the 2024 Form PF Amendments will impact

all categories of private fund advisers. These include, but are not limited to, advisers to hedge

funds, private equity funds, real estate funds, securitized asset funds, liquidity funds, and venture

capital funds. 9

As discussed above, the Commissions has extended the compliance date for the 2024

Form PF Amendments on several occasions, most recently to allow Form PF filers to continue to

See 2024 Adopting Release.

file the Current Form PF until the Current Compliance Date of October 1, 2026. This final rule

will extend the compliance date for the 2024 Form PF Amendments to July 1, 2027, to provide

time for the Commissions to consider comments on the 2026 Proposed Form PF Amendments

and take any further action. The additional extension will affect all advisers required to file the

2024 Form PF Amendments. 10 The primary benefit of the delayed compliance date is that it will

allow advisers to avoid the costs associated with any of the 2024 Form PF Amendments that

could be eliminated or modified if the Commissions adopt the 2026 Proposed Form PF

Amendments in whole or in part. This benefit will be reduced to the extent that advisers have

already incurred any portion of the initial costs associated with such amendments. 11 If the

Commissions ultimately determine not to adopt the 2026 Proposed Form PF Amendments, the

delayed compliance date will save the affected advisers the incremental costs of complying with

the 2024 Form PF Amendments during the nine-month extension, and will delay any initial costs

associated with those amendments that advisers have not yet incurred. 12

Extending the compliance date to July 1, 2027, will delay the realization of any economic

benefits from the new information in the 2024 Form PF Amendments that otherwise would have

been available to the Commissions and the Financial Stability Oversight Council (the

“FSOC”). 13 For example, if significant market events occur during the extension period, the

See 2024 Adopting Release for baseline statistics on Form PF filers.

While many advisers may have already incurred a large fraction of the initial costs associated with

developing the new reporting systems in order to meet previously extended compliance dates, some

advisers may still incur a remaining fraction of this cost as they finalize the development and testing of

these systems before July 1, 2027.

See 2024 Adopting Release for PRA compliance costs associated with the 2024 Form PF Amendments.

Specifically, the 2024 Form PF Amendments were designed to facilitate two primary goals the SEC sought

to achieve with reporting on Form PF as articulated in the 2024 Adopting Release, namely: (1) facilitating

FSOC’s understanding and monitoring of potential systemic risk relating to activities in the private fund

benefits associated with the new information in the 2024 Form PF Amendments that the

Commissions and the FSOC would have otherwise been able to use for oversight purposes

during the extension period will be forgone.

The extension of the compliance date also will further delay the accrual of any effects on

market efficiency, competition, and capital formation described in the 2024 Adopting Release.

As an alternative, we could have provided a shorter or longer compliance date extension (e.g., 6month or 1-year extension). However, a shorter extension may not have provided enough time

for the Commissions to consider comments on the 2026 Proposed Form PF Amendments and

take any further action. Conversely, a longer extension would delay the accrual of any benefits

from the augmented information in the 2024 Form PF Amendments longer than necessary if the

Commissions ultimately determine not to adopt the 2026 Proposed Form PF Amendments.

III.

PROCEDURAL AND OTHER MATTERS

The Administrative Procedure Act (“APA”) generally requires an agency to publish

notice of a rulemaking in the Federal Register and provide an opportunity for public comment.

industry and assisting FSOC in determining whether and how to deploy its regulatory tools with respect to

nonbank financial companies; and (2) enhancing the SEC’s abilities to evaluate and develop regulatory

policies and improving the efficiency and effectiveness of the SEC’s efforts to protect investors and

maintain fair, orderly, and efficient markets. The 2024 Form PF Amendments were designed to (1) provide

solutions to potential reporting errors and issues of data quality when analyzing Form PF filings across

advisers and when analyzing multiple different regulatory filings; (2) help Form PF more completely and

accurately capture information relevant to ongoing trends in the private fund industry in terms of

ownership, size, investment strategies, and exposures; and (3) take certain steps to streamline certain

reporting and reduce certain reporting burdens without compromising investor protection efforts and

systemic risk analysis. See Initial Compliance Date Extension Release. See also 2024 Adopting Release, at

section IV.C.1.

This requirement does not apply, however, if the agency “for good cause finds . . . that notice

and public procedure are impracticable, unnecessary, or contrary to the public interest.” 14

The Commissions, for good cause, find that notice and solicitation of public comment to

further extend the compliance date for the 2024 Form PF Amendments are impracticable,

unnecessary, or contrary to the public interest. 15 This extension does not impose any new

substantive regulatory requirements on any person and merely reflects the further extension of

the compliance date for the 2024 Form PF Amendments. For the reasons discussed above, an

extension of the compliance date to July 1, 2027, is needed to allow Form PF filers to avoid

certain potentially significant costs associated with aspects of the 2024 Form PF Amendments

that the Commission has proposed to amend and/or eliminate, while the Commissions consider

comments on the Proposed 2026 Form PF Amendments and whether to take further action.

For similar reasons, although the publication of a rule is generally required at least 30

days before its effective date, the requirements of 5 U.S.C. 553(d)(3) and 808(2) are satisfied

(notwithstanding the requirement of 5 U.S.C. 801) 16 and therefore the good cause exception

applies to this action. 17

5 U.S.C. 553(b)(B).

See 5 U.S.C. 553(b)(B) (stating that an agency may dispense with prior notice and comment when it finds,

for good cause, that notice and comment are “impracticable, unnecessary, or contrary to the public

interest”).

See 5 U.S.C. 553(d)(3) (the publication of a substantive rule may be less than 30 days before its effective

date for good cause found and published with the rule); 808(2) (if a Federal agency finds that notice and

public comment are impracticable, unnecessary or contrary to the public interest, a rule shall take effect at

such time as the Federal agency promulgating the rule determines). This rule also does not require analysis

under the Regulatory Flexibility Act. See 5 U.S.C. 604(a) (requiring a final regulatory flexibility analysis

only for rules required by the APA or other law to undergo notice and comment). Finally, this rule does not

contain any collection of information requirements as defined by the Paperwork Reduction Act of 1995

(“PRA”). 44 U.S.C. 3501 et seq. Accordingly, the PRA is not applicable.

See 5 U.S.C. 553(d)(3).

For purposes of Subtitle E of the Small Business Regulatory Enforcement Fairness Act of

1996 (also known as the Congressional Review Act), 18 the Office of Management and Budget

(“OMB”) has determined the final rule is not a “major rule.” OMB has determined that this

action is not a significant regulatory action as defined in Executive Order 12866, and therefore it

was not subject to Executive Order 12866 review. This action is an Executive Order 14192

deregulatory action.

Note: Form PF will not appear in the Code of Federal Regulations.

By the Commissions.

Dated: August 31, 2026

Christopher Kirkpatrick,

Secretary, Commodity Futures Trading Commission.

Vanessa A. Countryman,

Secretary, Securities and Exchange Commission.

NOTE: The following Commodity Futures Trading Commission (CFTC) appendix will not

appear in the Code of Federal Regulations.

CFTC Appendix to Form PF; Reporting Requirements for All Filers and Large Hedge

Fund Advisers; Further Extension of Compliance Date – CFTC Voting Summary

On this matter, Chairman Selig voted in the affirmative. No Commissioner voted in the

negative.

5 U.S.C. chapter 8.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.