On February 12th, the SEC released a notice to N-CEN and N-PORT filers to remind them of the temporary final rule which requires funds in larger fund groups (for example, fund groups with $1 billion or more in net assets) to maintain in their records the information that is mandated to be included in Form N-PORT in lieu of filing this form via EDGAR. The temporary final rule applies until April 1, 2019. Of key importance, the information the funds in larger fund groups maintain in their records will be subject to examination by the Commission. New Forms N-PORT and N-CEN were adopted by the SEC on October 13th, 2016 in an effort to enhance transparency and modernize reporting requirements for registered investment companies.
Larger fund groups will be required to file Form N-PORT via the EDGAR system by April 30th, 2019 for the period ending March 31, 2019. Smaller fund groups (fund groups will less than $1 billion in net assets) will be required to submit Form N-PORT by April 30th, 2020.
Compliance dates for Form N-Cen remain unaffected by this temporary final rule. Accordingly, N-CEN filers will still be required to begin submitting this form to the EDGAR System on June 1st, 2018. Both forms can be test filed before the compliance requirement dates. The following table shows the pilot phases for both forms:
| Pilot Phase |
Dates |
Forms |
| Pilot Phase 2 |
March 12, 2018 - May 31, 2018 |
N-CEN and NPORT |
| Pilot Phase 3 |
October 2018 - March 2019 |
N-PORT only |
Technical drafts for Forms N-CEN and N-PORT are available here to guide filers in constructing XML submissions. Form N-CEN can also be accessed through the EDGAR Filing Website. No live filings for Form N-CEN will be accepted before June 1st, 2018, and no live filings for Form N-PORT will be accepted before April 1st, 2019.
Filers are also reminded that test filings should not be submitted between 3:00 and 5:30 pm EST each day. In addition, confidential or identifying information should not be included in test filings. During these test periods, the SEC encourages filers to use fictional data for test filings. Form N-PORT filers should also be aware that the EDGAR System will not accept filings with greater than 200,000 holdings during the current testing period. Finally, the SEC accepts feedback, comments, and questions with regard to Forms N-CEN and N-PORT, their technical draft specifications, and their filing process. All correspondence should be emailed to StructuredData@sec.gov with the subject line “NPORT/NCEN Feedback”.
Beta versions of Forms N-CEN and N-PORT will be available in GoFiler within the coming weeks. Check back at the blog for more updates and news concerning the release and SEC requirements of these forms.
Sources:
Notice to Forms N-CEN and N-PORT Filers (www.sec.gov)
Investment Company Reporting Modernization (www.sec.gov)
Investment Company Reporting Modernization - Temporary Final Rule (www.sec.gov)
