CFTC and SEC extend Form PF compliance date to July 1, 2027

  • CFTC and SEC extended Form PF amendments’ compliance date to July 1, 2027.
  • The agencies have postponed the requirements four times amid private-fund industry opposition.
  • April’s proposal would raise the reporting threshold from $150 million to $1 billion.

The Commodity Futures Trading Commission and Securities and Exchange Commission extended the compliance date for amendments to Form PF from October 1, 2026, to July 1, 2027, marking the fourth postponement of the requirements. Form PF is a confidential filing used by certain SEC-registered private-fund advisers, including advisers also registered with the CFTC as commodity pool operators or commodity trading advisers. The reporting framework is intended to give regulators visibility into private funds’ holdings, leverage and risk exposures during periods of market volatility, helping them assess counterparty risk, margin pressure and potential systemic threats. Private-fund firms have opposed expanded disclosure requirements over concerns that sensitive investment strategies could be exposed. In an April 20, 2026, proposal, the agencies considered raising the private-fund asset threshold for Form PF reporting from $150 million to $1 billion, but that proposal has not been finalized. The extension also gives regulators time to review comments and avoid potentially significant implementation costs associated with provisions they have proposed to amend or eliminate.

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