The SEC Unveils New N-PORT Reporting Amendments for Registered Investment Companies

Yesterday, the U.S. Securities and Exchange Commission (SEC) stepped up reporting requirements for registered management investment companies (other than money market funds and small business investment companies) and exchange-traded funds (ETFs) organized as unit investment trusts.

Amendments to Form N-PORT will both increase the frequency of reporting and compress the reporting schedule for these funds to report detailed information about their portfolio holdings. Funds will be required to file Form N-PORT once a month, instead of every quarter, and within 30 days after the end of each month, instead of within 60 days after the end of the quarter. The publication schedule for these reports will also change: the SEC will publish N-PORT reports 30 days after firms file them instead of 60.

As a result, the SEC staff will be monitoring portfolio information that is only 30 days stale, and the public will have portfolio information that is only 60 days stale.

These reporting amendments enhance the SEC's ability to monitor markets, allowing them to understand markets better, spot market problems sooner, and engage with the Financial Stability Oversight Council more effectively. The compressed reporting schedule enhances investors' information usefulness to making investment decisions.

The SEC also adopted amendments to Form N-CEN to require funds that are subject to the liquidity rule (rule 22e-4) to identify and provide certain information about service providers they use to comply with that rule, as well as changes related to entity identifiers. This new requirement will allow the SEC staff to monitor and analyze current fund practices for liquidity risk management.

The compliance date for the amendments is November 17, 2025, 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.

Our guidance

The SEC's recent amendments to Form N-PORT reporting requirements present registered investment companies with the dual challenge of adapting to more frequent and compressed reporting timelines while maintaining compliance with enhanced regulatory standards. These changes demand heightened vigilance in monitoring portfolio holdings and liquidity risk management, as the SEC aims to improve market transparency and investor protection.

Registered investment companies must now prioritize developing and refining their internal controls, ensuring that reporting processes are robust enough to meet these new expectations. By focusing on these critical adjustments, companies can enhance their compliance framework, ensuring both resilience against regulatory challenges and continued trust from investors in a more demanding environment.

How we help

Our team is here to ensure your fund is well-prepared for these changes. Our Principal Financial Officer (PFO) services offer tailored support, guiding you through these regulatory changes with a hands-on, expert approach.

Our experienced Fund Officers work closely with our mutual fund and ETF clients to be integrated into their governance structure. Our PFOs collaborate with your board and audit committees to monitor compliance and make necessary disclosures. We provide detailed oversight of disclosure controls and procedures, supporting timely and accurate filings. Our PFOs play a critical role in the Sarbanes-Oxley (SOX) certification process, chairing and attending disclosure control committee meetings while reviewing and commenting on Forms N-PORT, N-CSR, and N-CEN.

Our professionals stay ahead of regulatory trends, offering actionable insights to keep your fund strategically positioned considering the SEC’s latest amendments. Contact us today to learn how we can help your fund meet the SEC’s new requirements with confidence.

Contact us