On September 1, 2026, the U.S. regulatory system hit the brakes once again. The CFTC announced that the SEC and CFTC jointly passed final rules, postponing the compliance date of the Form PF amendment originally set to take effect on October 1, 2026, to July 1, 2027. This is the fourth time this regulation, specifically designed to track private fund leverage and risk exposure, has been put on "delay." As the timeline continues to be pushed back, multiple former senior regulatory officials from the SEC and CFTC (including former CFTC Chairman Chris Giancarlo) have already alerted in a commentary letter: if the regulatory boundaries are misdrawn, the U.S. may not only continue to push the market overseas but may also watch a roughly $90 trillion perpetual contract market opportunity slip away. One factor is the regulators’ choice to slow down the implementation pace collaboratively, while another is the urgency emphasized by former officials that "similar risks should have similar regulatory treatment." The fourth delay of Form PF forces these two completely different senses of time onto the same timeline.
Form PF aims to see who is leveraging
On February 8, 2024, the SEC and CFTC jointly passed the Form PF amendment, addressing a simple question: who is quietly leveraging? Form PF was originally designed as a disclosure form for private funds, especially hedge funds, to report information to regulators. This revision further emphasized "risk exposure"—during times of severe market volatility, regulators hope to quickly discern the overall positions, nested leverage, margin structure, and main counterparties from these reports.
From the regulators' perspective, Form PF is not just a simple report but a radar screen used to capture potential systemic risks. By statistically unifying the leverage ratios, margin usage, and counterparty concentration of private funds, they aim to identify in advance which links might be the first to break during the next major tremor. This logic extends beyond traditional markets: for those funds leveraging through various derivatives, or even perpetual contracts, even if the underlying assets are on-chain and positions are on crypto derivatives platforms, the associated risks will still reflect in the form of total leverage and margin pressure in Form PF's view. This becomes an essential piece of the puzzle in monitoring risks in perpetual contracts and other crypto derivatives markets.
Four delays: regulators choose to wait and see
On the timeline, the Form PF amendment resembles a "regulatory alarm clock" that has been repeatedly pushed back. When the SEC and CFTC officially approved the amendment on February 8, 2024, they left ample buffer time for the market—originally setting the main compliance date for October 1, 2026. Subsequently, under the narrative of “prudent” and “gradual progress,” regulators continuously adjusted the alarm clock later. Until September 1, 2026, the CFTC announced that both agencies, in the form of a joint final rule, would again postpone the compliance date from October 1, 2026, to July 1, 2027. This marks the fourth delay specifically aimed at this disclosure regulation and a clear adjustment in pace jointly signed by the SEC and CFTC.
For private funds, this "wait and see" approach releases a signal that the regulatory stance is becoming unified—at least on this Form PF line, the SEC and CFTC chose to lock in the same timetable with a joint rule, indicating that the cooperation framework between these two major agencies regarding risk monitoring and information reporting has taken shape. On the other hand, it extends the period of uncertainty: compliance teams cannot fully complete system transformations and data connections by 2026 as originally planned, and they find it difficult to ignore a disclosure obligation that has been approved and reiterated multiple times. They can only probe repeatedly between investment and observation, which makes market participants' expectations regarding how to plan leverage, position disclosure, and cross-market risk reporting in the coming years increasingly vague.
Former regulatory officials warn: $90 trillion may flow overseas
As the regulatory timeline drags on, multiple former senior SEC and CFTC officials jointly issued a commentary letter, one of the signatories being former CFTC Chairman Chris Giancarlo, who has been regarded as "crypto-friendly." The sharpest point in the letter questions the current method of boundary delineation in regulation: in their view, if different market participants assume similar risks but are subjected to completely different rules due to licensing, institutional affiliation, or product forms, this not only deviates from the fundamental principle that "similar risks should have similar regulatory treatment" but also effectively pushes compliance activities offshore with erroneous boundaries.
The letter warns that if regulatory misalignment persists, the U.S. may watch a perpetual contract market estimated at around $90 trillion take shape overseas, accumulating liquidity and price discovery functions through offshore platforms, while domestic regulators are still engaged in disputes over boundaries. In the eyes of these former officials, no matter how much the compliance date of Form PF is postponed, one fact remains unchanged: if the lines are drawn incorrectly, the market will grow elsewhere, and the U.S. will ultimately pay the price of lost competitiveness and diminished regulatory influence.
Testing perpetual contracts in the U.S., local regulation remains fragmented
Almost simultaneously with the former officials' mention of the "$90 trillion perpetual contract forming overseas," reports indicate that the CFTC is seeking to introduce perpetual contracts into the U.S. market, seen as an effort to find a "local landing" testbed for this crypto derivative under the existing futures regulatory framework. According to a single source, Trump publicly stated that the CFTC Chairman is working to bring the crypto trading platform Hyperliquid to the U.S. This statement, regardless of eventual progress, transmits a political signal: the U.S. is indeed not disinterested in this new type of product, and both regulators and political figures are seeking entry points.
The problem is, on the other side, the Form PF amendment keeps delaying its effective date, and the system initially meant to monitor private fund leverage and risk exposure will not actually come into effect until after July 1, 2027. This creates a dichotomy of a cautious extended timeline on one hand while attempting to introduce perpetual contracts on the other. Behind this is the already multi-faceted regulatory landscape in the U.S.: securities, futures, and crypto derivatives fall under different agencies and rule systems. While the CFTC and SEC show a cooperative framework on Form PF, there remain divisions in terms of specific product identification and jurisdictional boundaries. The consequence is that the same types of perpetual contract risks may face entirely different requirements under different regulatory channels, leaving institutional choice space in the market and fragmenting the principle of "similar risks should have similar regulatory treatment" on a practical level.
As the U.S. hesitates, where will perpetual contracts stand?
From the passage of the Form PF amendment by the SEC and CFTC on February 8, 2024, to the repeated extension of compliance dates, ultimately on September 1, 2026, the joint push to July 1, 2027, these four delays signal a strong message: the regulatory tier chooses to continue observing how to define and penetrate leverage risks. Conversely, multiple former senior SEC and CFTC officials (including former CFTC Chairman Chris Giancarlo) have reminded in the commentary letter that if the regulatory boundaries are improperly drawn, the U.S. may miss out on a perpetual contract market estimated at $90 trillion, reiterating that "similar risks should have similar regulatory treatment"—yet the reality is that tools for cross-securities, futures, and crypto derivatives risk disclosure are still being continually postponed. Against the backdrop of global perpetual contract trading being widely viewed as primarily developing on offshore platforms (this judgment is closer to general industry recognition rather than new statistical data), the U.S. hesitation can easily be interpreted as an automatic outsourcing of competitive advantage. At the same time, reports indicate that the CFTC is seeking to introduce perpetual contracts domestically and is attempting to bring the crypto trading platform Hyperliquid to the U.S., indicating that regulators are not without willingness but have yet to finalize unity on paths and divisions of labor. What truly needs to be continuously observed next is whether these three clues can converge simultaneously: will Form PF land as planned on July 1, 2027; can the SEC and CFTC establish a more consistent risk framework for cross-market products; and what specific landing path will the CFTC choose in its experiment of bringing perpetual contracts to the U.S.
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