September 24, 2026
What happened?
On August 31, 2026, the Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”) further extended the compliance date for the amendments to Form PF from October 1, 2026, until July 1, 2027.
This is the latest in a series of twists and turns for the amended rule that would require SEC-registered advisers to private funds, particularly advisers to hedge funds, to report additional information on Form PF. The rule’s original compliance deadline was March 12, 2025, the first extended deadline was June 12, 2025, the second extended deadline was October 1, 2025, and the third extended deadline was October 1, 2026. Now, the fourth extended deadline is July 1, 2027. See our prior coverage here.
This rule was finalized during the Gensler chairmanship at the SEC with a compliance date falling under the new administration. Under Atkins, not only has the rule been extended four times, but the SEC and CFTC also jointly proposed a rule to simplify Form PF by reducing both the number of advisers required to file and the amount of information reported in the filing. We now have a finalized rule that would expand Form PF requirements stuck on extension, while a new proposal to contract requirements is waiting in the wings.
What does this mean for me?
Last September, then commissioner Caroline Crenshaw called the third extension of the Form PF compliance date a “repeal by extension.” She cited court precedent that agencies have a responsibility to determine whether final rules will be rescinded, repealed, modified, or defended in litigation. Now, a full year later, the same final rule has been extended a fourth time.
The industry will have to wait and see what the SEC and CFTC will do. Extending the burdensome amendments a fourth time gives the agencies even more time to consider public comments on the proposed rule that would provide regulatory relief for many Form PF filers.
We will continue to monitor regulatory updates and new developments that impact investment advisors. If you have questions, contact us. Fairview is here to help.
