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SEC's New Form N-CEN Filing Deadline Kicks in for Some Funds

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Mutual fund firms and other registered investment companies with a fiscal year that ended June 30 are busy filing the new Form N-CEN with the Securities and Exchange Commission, as the deadline to do so kicked in on Thursday.

As of Tuesday, 144 of these investment companies have filed Form N-CEN with the securities regulator.

The SEC also announced on Sept. 11 XML schema changes for Form N-PORT and N-CEN that take effect Oct. 1.

Form N-CEN requires registered investment companies, other than “face-amount certificate companies,” to annually report certain census-type information to the Commission in a structured data format.

The filing date for Form N-CEN depends on the filers’ fiscal year-end. Form N-CEN should be filed not later than 75 days after the close of the fiscal year for which the report is being prepared, the SEC states.

The SEC adopted a temporary final rule in February requiring funds in larger fund groups  (i.e., fund groups with $1 billion or more in net assets) to maintain in their records the information that is required to be included in Form N-PORT, in lieu of filing reports with the commission, until April 1, 2019.

The commission adopted Form N‑PORT to require registered investment companies to report enhanced information about their monthly portfolio holdings in a structured data format.

Filing of the form through the EDGAR system will begin in April 2019 for larger fund groups and in April 2020 for smaller fund groups.

Both forms are designed to modernize the reporting and disclosure of information by registered investment companies.

“N-CEN ushers in a new level of complexity around data filing for investment managers, and Donnelley Financial has made significant investments in technology and resources to ensure our clients successfully comply with the new regulations,” said Eric Johnson, president of Global Investment Markets at Donnelley Financial Solutions, in a statement.

A provider of risk and compliance solutions, Donnelly said it’s using its ArcFiling platform to help firms file the XML-based Form N-CEN, along with the upcoming Form N-PORT, and is on track to complete N-CEN filings covering approximately 4,000 investment funds in the first year of the new requirement.

Form N-CEN, Johnson said, “is larger in scope than the Form N-SAR it replaces, containing approximately 500 questions for filers to respond to, many of which are new and cover both finance and legal functions.”

Donnelley Financial advises filers to load data “weeks in advance and validate it with a comprehensive filing solution such as ArcFiling or to submit a test filing to identify any errors or issues that must be resolved before the actual filing. Because the data is interdependent, creation of a valid XML file can be a challenge for some filers.”

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