Investment Company Institute (ICI) President and CEO Eric Pan released the following statement regarding the Securities and Exchange Commission’s (SEC) vote to adopt changes to Form N-PORT reporting requirements and liquidity risk management program guidance.
“ICI has raised serious concerns about moving portfolio holdings disclosure on Form N-PORT from quarterly to monthly, as this will open fund managers to a greater risk of predatory trading that will harm fund shareholders, without any corresponding benefit. ICI has also questioned the SEC’s requirement to have funds file these holdings within 30 days of month end given the volume of information required and the SEC’s history of data security breaches. Additionally, the Commission continues to give little consideration to the disproportionate burden of its rulemaking on smaller fund complexes. The SEC should have reproposed the new reporting requirements to ensure adequate public comment on these concerns.
“We also will review today’s new liquidity risk management program guidance to understand how it will impact funds and their shareholders. It is important to note that funds currently have robust liquidity risk management programs as a matter of practice and existing regulatory requirements.”
Source: ICI
SEC Adopts Reporting Enhancements for Registered Investment Companies and Provides Guidance on Open-End Fund Liquidity Risk Management Programs
The Securities and Exchange Commission adopted amendments to reporting requirements on Form N-PORT to provide the Commission and investors with more timely information about certain registered investment companies (funds). Form N-PORT reports provide important information about a fund’s portfolio holdings and related information to help assess a fund’s risks. The amendments will provide the Commission with timelier information about funds’ portfolio investments, which will promote more effective regulatory monitoring and oversight of the fund industry for the benefit of fund investors. The amendments also will triple the amount of Form N-PORT data available to investors in a given year, enhancing investors’ ability to review and monitor information about their funds’ portfolios.
“Reliable, accessible data benefits everyone,” said SEC Chair Gary Gensler. “These amendments will benefit investors through greater transparency of funds’ investment portfolios and improve the Commission’s oversight of the asset management industry.”
The Form N-PORT amendments will require funds that are required to report on the form—generally registered open-end funds, registered closed-end funds, and exchange-traded funds organized as unit investment trusts—to file reports on Form N-PORT on a monthly basis within 30 days after the end of the month to which they relate. Currently, funds file these monthly reports on a quarterly basis within 60 days after quarter-end. The amendments will also make funds’ monthly reports on Form N-PORT available to the public 60 days after the end of each month instead of every third month of a quarter only.
In addition, the Commission adopted reporting amendments and provided guidance related to open-end fund liquidity risk management program requirements. Specifically, the Commission adopted amendments to Form N-CEN requiring open-end funds to report certain information about service providers used to fulfill liquidity risk management program requirements so that the Commission can track certain liquidity risk management practices. The Commission also provided guidance related to certain aspects of open-end fund liquidity risk management program requirements to address questions raised through outreach and monitoring.
The amendments to Forms N-PORT and N-CEN will become effective on November 17, 2025. Funds generally will be required to comply with the amendments for reports filed on or after that date, except that fund groups with net assets of less than $1 billion will have until May 18, 2026, to comply with the Form N-PORT amendments.
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