The Securities and Exchange Commission has released updated FAQ guidance regarding investment company reporting modernization reforms as they relate to forms N-PORT and N-CEN.
The agency’s Division of Investment Management’s latest update on Wednesday relates to the investment company reporting modernization reforms adopted in October 2016 and revised in December 2017.
IM staff said they expect to update the document from time to time to include responses to additional questions.
As to the respective compliance dates for Form N-PORT and Form N-CEN, the IM division explained that for Form N-PORT, larger entities — 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 — has a compliance date of June 1, 2018.
Funds must file reports on Form N-PORT no later than 30 days after the end of each month. Compliance should be based on reporting period-end date.
Under a modified approach, larger entities will 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.
Like all fund records under the Investment Company Act, this information is subject to examination by commission staff, the division states.
“As a result, funds in larger fund groups that previously would have been required to submit their first reports on Form N-PORT on EDGAR no later than July 30, 2018 (for the period ending June 30, 2018) will now be required to submit their first reports on EDGAR no later than April 30, 2019 (for the period ending March 31, 2019),” the FAQ states.
Smaller fund groups will now submit their first reports on Form N-PORT by April 30, 2020 (for the period ending March 31, 2020), and are not subject to a requirement to prepare and retain as a record the information required on Form N-PORT.
The compliance date for Form N-CEN is June 1, 2018 for all funds.
Funds must report on Form N-CEN within 75 days of the fund’s fiscal year-end (75 days after the calendar year-end for unit investment trusts).
Compliance should be based on reporting period-end date.
For instance, the IM Division stated that a fund with a June 30 fiscal year-end should have made its first filing for the year ended June 30, 2018, on Form N-CEN by Sept.13, 2018.
A fund with a May 31 fiscal year-end would not need to make its first filing on Form N-CEN until the fiscal year ending May 31, 2019 (with such filing being made within 75 days of that date) because May 31, 2018, is prior to Form N-CEN’s compliance date, according to the SEC.
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