The SEC and CFTC are turning up the heat on crypto fund reporting. The SEC's 2026 Unified Agenda lists Form PF amendments as an active item, while the CFTC recently sought public comment on 24/7 futures and perpetuals — a move that could reshape how funds report risk. For the over 300 crypto funds launched since 2020, the clock is ticking.
The Form PF problem
Form PF assumes end-of-day marks and weekday operations. Crypto trades 24/7. That mismatch creates real reporting risks. Many funds fix a daily NAV timestamp at 00:00 UTC and use multi-venue pricing, but price fragmentation across centralized and decentralized exchanges makes it tough to get a defensible point-in-time price. Event clocks for current reporting — often 72 hours — don't pause for weekends or holidays. That means compliance fire drills when a flash crash hits on a Saturday night.
DeFi's ambiguous counterparties
Counterparty definitions in DeFi are a mess for Form PF. Is the counterparty a protocol, a liquidity pool, or a smart contract? Regulators haven't given clear guidance, and funds are left guessing. The ambiguity adds another layer of risk when reporting exposure to decentralized platforms. It's not just a paperwork problem — it could mask systemic risk if funds classify DeFi positions inconsistently.
What the CFTC is asking
The CFTC's comment period on 24/7 futures and perpetuals ended July 27, 2026. The agency asked how continuous trading should work for standard futures — a question that directly affects crypto funds that hedge or trade these products. The fact that they're even asking signals a shift toward recognizing that markets don't sleep. For funds, that means the old end-of-day reporting model may be on its way out.
The SEC's Form PF amendments are still an active item on the 2026 agenda. No proposal has been published yet, but the direction is clear: regulators want more frequent, more granular data from crypto funds. The comment period may be closed, but the rulemaking is just getting started. Funds should expect more clarity — and more requirements — in the months ahead.
