Non-Public Form N-PORT: Changes to Filing Date

Keeping up with the latest changes to filing requirements is a critical element of compliance at any firm.

Non-Public Form N-PORT: Changes to Filing Date 

In late February, the Securities and Exchange Commission (SEC) announced that it had altered the submission deadlines for registered investment companies to file non-public monthly reports on Form N-PORT, a new form used to report both public and non-public fund portfolio holdings to the SEC that utilizes a structured data format.

Changes to Form N-PORT: The Specifics

Until recently, firms were required to file non-public monthly reports with the SEC within 30 days from the end of each month.

Going forward, funds must maintain the relevant information in their records and file 3 monthly reports simultaneously with the commission within 60 days from the end of each fiscal quarter.

The non-public monthly reports on Form N-PORT for the first and second months of the fiscal quarter will remain non-public.

However, the monthly report for the third month will become public information immediately upon filing, as opposed to being filed non-publicly within 30 days from the end of the fiscal quarter and public access being granted 60 days from the end of the fiscal quarter.

While this might seem concerning initially, it’s important to note that the amount of information made available to the public on Form N-PORT and the timing of its release to the public will not change.

To summarize, firms will now hold those reports and file them together quarterly, which should aid the SEC in their attempts to streamline data management and reduce cyber risk.

Staying Informed to Maintain Compliance

For larger fund groups, the electronic filing of Form N-PORT through the EDGAR system will begin in April 2019, according to the SEC’s recent press release.

For smaller groups (total net assets of $1 Billion or under), the new protocol will take effect in April 2020.

Understanding changes to filing requirements and regulations is a critical first step toward fulfilling your firm’s compliance obligations and steering clear of enforcement.

If you’re having difficulty determining what these changes to Form N-PORT mean for your firm, or if you need assistance in reviewing your policies and procedures to ensure compliance is maintained, Core Compliance & Legal Services, Inc. can help.

Contact us here for assistance with these or any other legal needs.