On September 17, 2025, the SEC and the CFTC voted to extend the compliance date for amendments to Form PF for a third time, resulting in a new compliance date of October 1, 2026. Form PF is the confidential reporting form filed by certain SEC-registered private fund investment advisers, including those that also are registered with the CFTC as commodity pool operators or commodity trading advisers, to report confidential information about the private funds that they advise. The amendments to Form PF were adopted on February 8, 2024 with an original compliance date set for March 12, 2025. On January 29, 2025, the SEC and the CFTC extended the compliance date of the Form PF amendments to June 12, 2025 in order to address certain challenges associated with the timing of reporting cycles for Form PF, and on June 11, 2025 they further extended the compliance date to October 1, 2025 in order to provide more time for filers to develop and test their Form PF reporting systems.

In this third extension of the compliance date, to October 1, 2026, the SEC and the CFTC stated that more time is needed to complete a substantive review of Form PF in accordance with the January 20, 2025 Presidential Memorandum directing agencies to consider postponing the effective date of any rules that had been published in the Federal Register, or that were issued but had not yet taken effect, for the purpose of reviewing any questions of fact, law, and policy that the rules may raise. As a result, filers may continue to use the current version of Form PF until October 1, 2026.

The joint final rule extending the compliance date is available here, and the related SEC press release is available here.