On August 31, 2026, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) (collectively, the “Commissions”) jointly extended the current date for compliance with the February 2024 amendments to Form PF (the “Amendments”) from October 1, 2026, to July 1, 2027. This further extension gives the SEC and CFTC additional time to consider comments received on the Commissions’ April 2026 proposal to modify or eliminate certain portions of the Amendments. Until the new compliance date, Form PF filers may continue to use the version of Form PF in effect before the Amendments. For more details on the April 2026 proposal, see our client alert.
The Commissions explained that the additional compliance period will not only give them time to consider comments received on the April 2026 proposal but also allow Form PF filers to avoid incurring potentially significant implementation costs for Form PF changes that may ultimately be revised or eliminated. The extension also preserves sufficient time for Form PF filers to comply with the Amendments if the Commissions do not adopt the April 2026 proposal in whole or in part.
Investment advisers should continue to make required Form PF filings on the existing form and to monitor the Commissions’ actions related to the Amendments.
Please contact the authors of this alert or your usual MoFo contact with any questions.