SEC Proposes Changes to Form N-Port

Overview:

• On February 18, 2026, the SEC proposed amendments to Form N-PORT that would largely roll back or revise elements of the SEC’s 2024 Form N-PORT amendments, which had contemplated monthly public Form N-PORT reporting on an accelerated 30-day deadline⁽¹⁾. Although the 2024 amendments were adopted, the SEC delayed their compliance dates before they took effect.
• If the new proposal is adopted, Form N-PORT would be required to be filed monthly, due 45 days after each month-end, but the SEC would make public only the third month’s data in each quarter. The proposal would also reduce the amount and granularity of information funds must report, including eliminating certain data elements and simplifying select risk and return disclosures.
• Concurrently, the SEC extended the compliance dates for the “Names Rule” related N-PORT reporting requirements to Nov. 17, 2027 for fund groups with net assets of $10 billion or more, and to May 18, 2028 for fund groups with less than $10 billion.

Rule’s Key Elements:

• Covered Funds:
  • Form N-PORT reporting requirements cover most registered investment companies, which include exchanged-traded funds organized as unit investment trusts and registered open and closed-end funds (including Interval Funds and Tender-Offer Funds).
  • Business Development Companies (“BDCs”), which are generally not required to submit reports to Form N-PORT, are not impacted by the new proposed requirements.

• Key Changes from Pre-2024 Amendments:
  • Filing timeframe: Prior to the 2024 amendments, Form N-PORT was filed quarterly, with reports for each month of a registered fund’s fiscal quarter due no later than 60 days after quarter-end. The 2024 amendments shifted to a monthly filing cadence, with each month’s report due no later than 30 days after month-end. Under the proposed amendments, funds would still file monthly, but the deadline would be extended to no later than 45 days after month-end.
  • Public availability / publication frequency: Prior to the 2024 amendments, only the information reported for the third month of a registered fund’s fiscal quarter became public 60 days after quarter-end. The 2024 amendments would have made information reported for each month publicly available 60 days after month-end. Under the proposed amendments, public availability would again be limited to information for the third month of the fiscal quarter, which would be made public 60 days after fiscal quarter-end.
  • Content of the reports: The proposal would simplify and reduce Form N-PORT required reporting by narrowing certain risk and performance metrics and eliminating certain information collected on registered funds’ compliance with names-related regulatory requirements, non-derivative instrument payoff profiles, convertible bond details, and the basis for assigning multiple liquidity classifications to a single holding.

Takeaways:

• Reduction but Not Elimination of Operational Requirements: The proposal would streamline certain Form N-PORT content requirements, easing some preparation burdens, but if adopted it would still require fund managers to shift from quarterly to monthly reporting. While it provides fifteen additional days to file compared with the 2024 amendments, it would still increase filings from four to twelve per year and reduce the days to prepare by 25% versus the current quarterly/60-day framework, heightening the need for automation and less reliance on manual workflows.
• Reduced Public Dissemination of Fund Information: The proposal appears responsive to industry concerns that more frequent public holdings disclosure could facilitate predatory trading and increase costs for fund shareholders. While certain fund information would still become public, information publicly released would be more limited in nature and would not occur on a monthly basis.

_{(1)Release No. IC-35963; File No. S7-16-22}