SEC Finalizes New Registered Fund Reporting Requirements

What Happened

Last week, the SEC adopted amendments to Form N-PORT which will require registered funds to file monthly reports on their fund’s holdings and risks rather than the current quarterly filing. Additionally, the SEC finalized changes to Form N-CEN that will require open-end funds to report information about the service providers used for their liquidity risk management programs.

The SEC sees these changes as improving regulatory oversight while providing investors with more information to make investment decisions, despite acknowledging the costs associated with these rules.

Key Takeaways

• Form N-PORT Filing

  • The form will continue to cover portfolio holdings and related information on the fund’s risks

  • Reports must be filed within 30 days after month-end

  • These reports will be made public 60 days after month-end

• Form N-CEN on Liquidity Service Providers

  • Funds must annually report the following on their liquidity service providers:

    • Legal name and entity identifier

    • Location

    • Asset classes that the service provider provides classifications for

    • Indicate whether the service provider was hired or terminated during the reporting period

• Swing Pricing Proposal

  • In response to harsh criticism on the swing pricing component of the rules, the SEC chose to exclude it from the final version

  • However, the SEC plans to reissue a new Swing Pricing proposal in 2025

• Compliance Date Timelines

  • Funds with over $1bn in net assets must comply with the new reporting requirements by November 17, 2025

  • Smaller funds must comply by May 18, 2026

CCG’s Guidance

• Engage your compliance, operations personnel, and your service providers to assess the feasibility of increased filing frequencies.

• Identify the service providers that are being used to fulfill the liquidity risk management program requirements.

• Amend policies and procedures to conform with the SEC’s new requirements.

In an ever-changing regulatory landscape, preparation is key. The SEC’s focus on registered funds and additional reporting requirements serves as a reminder of the volume, velocity, and complexity of the new regulation promulgation.

The Chenery Compliance team is here to help you navigate these changes and ensure your firm is prepared for the inevitable SEC exam.