ARTICLE
14 December 2017

SEC Delays Compliance Dates For Form N-PORT Filing

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
Smaller fund groups will be required to begin submitting reports on Form N-PORT by April 2020.
United States Corporate/Commercial Law

The SEC issued a temporary final rule requiring larger fund groups to maintain in their records the information required to be included in Form N-PORT, in lieu of filing reports with the SEC, until April 2019. Smaller fund groups will be required to begin submitting reports on Form N-PORT by April 2020.

Form N-PORT is to be used by registered investment companies to report information about monthly portfolio holdings to the SEC. Form N-PORT filings will be required for all registered management investment companies, excluding money market funds and small business companies, as well as unit investment trusts that operate as exchange-traded trusts. The rule mandates that such companies report complete portfolio holdings and other information to "facilitate risk analysis and other [SEC] oversight." Form N-PORT will be filed through EDGAR.

The first six months of Form N-PORT filings for larger funds will not be made public. The SEC will also require continued filing of Form N-Q, which was previously rescinded, until the compliance dates for Form N-PORT.

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