On Friday, December 8, 2017, the SEC modified the initial reporting requirement for Form N-PORT, giving the agency time to review data security for EDGAR and its other systems. For larger firms, the compliance deadline remains the same, but submission for the first nine months has been delayed. For smaller firms, the compliance and submission deadlines have been delayed by nine months.
The press release and temporary final rule can be accessed here:
For larger firms (funds that together with other investment companies in the same “group of related investment companies” have net assets of $1 billion or more as of the end of the most recent fiscal year of the fund), the compliance date remains June 1, 2018 and the first reporting period remains the month of June 2018 (due July 30, 2018). However, for the first nine months of reporting — until the March 2019 reporting period (due April 30, 2019) — firms will not submit electronically via EDGAR. Instead, firms will maintain the reports in their records and make them available to the SEC upon request.
This modified reporting regime also applies to the Form N-PORT questions added as a result of the Liquidity Risk Management Programs adopting release. The deadline for those questions remains the same.
As before, the first 6 months of reporting via EDGAR will remain non-public. Thus, reporting for March 2019 (due April 30, 2019) through August 2019 (due September 30, 2019) will be non-public. As before, portfolio information attached as exhibits for Form N-PORT for the first and third quarters of a fund’s fiscal year will still be made public during this 6-month period.
For smaller firms, the compliance date is delayed by nine months so that smaller firms will still benefit from starting one year after larger firms. The new compliance date is March 1, 2020, and the first reporting period is March 2020 (due April 30, 2020). The first report will be submitted electronically via EDGAR.
Until firms are submitting Form N-PORT via EDGAR (March 2019 reporting period for larger firms and March 2020 reporting period for smaller firms), firms must continue to report Form N-Q. This means that starting June 1, 2018, larger firms must prepare reports for both Form N-Q and Form N-PORT. The new rescission date for Form N-Q is May 1, 2020, so that smaller firms can submit their final Form N-Q report for the month of February 2020.
Correspondingly, the compliance dates for the amendments to the certification requirements of Form N-CSR will be March 1, 2019 for larger firms and March 1, 2020 for smaller firms.
There are no modifications to the Form N-CEN reporting requirements. Firms must still report via EDGAR.
While these changes delay the electronic submission deadline, larger firms will still need to be prepared to comply with Form N-PORT’s requirements as of June 1, 2018. In practice, this means that firms should continue their Form N-PORT preparations according to the schedule in place prior to the December 8, 2017 announcement.
Download a PDF version of this overview here: http://bit.ly/2C7a42v
[i] This report and all reports submitted before April 30, 2019 will not be electronically submitted to EDGAR. Instead firms will maintain the reports in their records and make them available to the SEC upon request.
[ii] The first 6 months of EDGAR reporting (for March 2019 through September 2019) will remain non-public, except that portfolio information attached as exhibits for the first and third quarters of a fund’s fiscal year will still be made public.