(Article from Registered Funds Regulatory Update, July 2025)
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The SEC recently announced an extension of the compliance dates for Form N-PORT reporting requirements adopted in August 2024. Under the extension, registered funds with $1 billion or more in assets must begin disclosing fund portfolio holdings information on a monthly rather than quarterly basis starting November 17, 2027, instead of November 17, 2025. Smaller funds must begin disclosing on May 18, 2028, instead of May 18, 2026.
The extension allows the SEC to review the Form N-PORT amendments in accordance with an Executive Order issued by President Trump in January 2025, directing agencies to postpone the effective dates of rules that had been issued but had not yet taken effect. This action also comes after the Registered Funds Association filed a petition in the Fifth Circuit Court of Appeals seeking review of the final amendments to Form N-PORT. In February 2025, the Court granted the SEC’s motion to stay the proceedings while the SEC conducts its review. Also in February 2025, the ICI expressed concerns about the potential negative impacts of more frequent public disclosure of fund holdings.
In its release announcing the Form N-PORT compliance date extensions, the SEC indicated it will consider the costs and benefits identified in its 2024 Adopting Release. The SEC also noted that if it determines no further amendments to Form N-PORT are needed after completing its review, the delayed compliance dates will provide funds with sufficient time to comply with the new requirements. Alternatively, if the SEC decides to rescind the amendments or propose new amendments following its review, the delayed dates will reduce costs that funds would have incurred to comply with the newly adopted amendments.
Notably, following a review by the SEC, the effective date for amendments to Form N-CEN (which requires open-end funds to report information about service providers used to comply with liquidity risk management program requirements) was not extended and will remain as November 17, 2025.
Form N-PORT and Form N-CEN Reporting; Guidance on Open-End Fund Liquidity Risk Management Programs; Delay of Effective and Compliance Dates, Release No. IC-35538 (Apr. 16, 2025), available at: https://www.sec.gov/files/rules/final/2025/ic-35538.pdf.