SEC and CFTC Move the Form PF Compliance Date to 1 July 2027: What Managers Should Do Now
On 31 August 2026 the Securities and Exchange Commission and the Commodity Futures Trading Commission issued a joint final rule, Release IA-6992, further extending the compliance date for the 2024 amendments to Form PF, the confidential reporting form for SEC-registered advisers to private funds. The rule took effect on 3 September 2026, the date it was published in the Federal Register. The new compliance date is 1 July 2027.
The deadline has moved several times. The amendments were adopted on 8 February 2024 with a compliance date of 12 March 2025. An extension announced on 29 January 2025 moved it to 12 June 2025, another in June 2025 moved it to 1 October 2025, and one in September 2025 moved it to 1 October 2026. The latest change adds nine months to that date. The agencies said a shorter extension might not have given them enough time to consider comments on the 2026 proposal and act on it, and that the delay lets advisers avoid significant costs tied to parts of the 2024 amendments that may be changed or removed.
The proposal behind the delay
On 20 April 2026 the two agencies jointly proposed further changes to Form PF, published in the Federal Register on 24 April 2026 with a comment deadline of 23 June 2026. The proposal would raise the filing threshold from $150 million to $1 billion in private fund assets under management, and raise the large hedge fund exposure reporting threshold from $1.5 billion to $10 billion. The agencies estimate that about half of current filers would be exempt, while the form would still cover more than 90% of private fund gross assets. The proposal is not final, so the current thresholds still apply until a final rule says otherwise.
A second development on 30 September 2026
On 30 September 2026 the SEC also voted on two proposals to widen retail investor access to private investments. One would amend Rule 205-3 so advisers to closed-end funds and business development companies could charge performance-based compensation of up to 20% of net capital gains. The other would change interval fund rules under Rule 23c-3 to allow a longer deferral before the first repurchase offer, monthly repurchase options and principles-based liquidity requirements. These are proposals, not final rules, and they do not change private fund rules directly. They do show a regulator focused on how private-market strategies reach a wider investor base, which may affect how LPs view evergreen and semi-liquid competitors.
Three ways this could play out
The outcome is uncertain, so plan for scenarios. If the proposal is adopted as written, a manager with private fund assets below $1 billion would fall under the new filing threshold and could stop filing, while one above it would file under the amended form. If the proposal is withdrawn or changed, the 2024 amendments would apply from 1 July 2027 to every registered adviser that files. If the agencies act in between, for example by keeping the thresholds and trimming the data fields, the work already done on data mapping would be partly reusable. In each case the 1 July 2027 date gives managers at least nine more months than before.
What private fund managers should do now
Step one: Confirm whether the rule applies to you. It covers SEC-registered advisers to private funds, including those also registered with the CFTC as commodity pool operators or commodity trading advisers. Exempt reporting advisers and managers that are not registered should confirm their status with counsel.
Step two: Reset your internal project plan. If your team was building to the 1 October 2026 date, move the 2024 amendment work to 1 July 2027, but keep your current Form PF filings on their existing schedule. The extension concerns the 2024 amendments only.
Step three: Test yourself against the proposed thresholds. Compare your private fund AUM with $1 billion, and note where a hedge fund strategy sits against $10 billion. Do not stop preparing on the assumption that the proposal passes.
Step four: Keep the 2024 data mapping in draft. The agencies may amend or remove parts of it, so archive the work instead of deleting it.
Step five: Align your LP communications. Update the regulatory reporting answer in your DDQ and your diligence pack so your administrator, your counsel and your investor materials say the same thing about timing.
Step six: Review fee and carry disclosure for consistency. The 30 September proposals touch performance-based compensation in registered vehicles. If your documents describe carried interest or performance fees, check that your marketing language matches the terms in your partnership agreement.
How this fits with other recent rule changes
Compliance calendars for private fund managers now have several moving parts. We covered the SEC's proposal to scrap the adviser pay-to-play rule and set out a broader view in our guide to AIFMD II and SEC marketing rules for first-time funds. Each one changes what should be in your compliance manual and your investor disclosures.
A practical habit is to keep one dated compliance log that lists each rule, its release number, its effective date, its compliance date and its owner. When a date changes, as it did here, you update one line. FundLinx members can track the regulatory dates that affect their LP conversations.
This article is a general summary and is not legal advice.
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