United States: But Wait, There’s More–Names Rule FAQ
By: Thoreau A. Bartmann and Christine Mikhael
On 19 February 2026, the United States Securities and Exchange Commission (SEC) published additional FAQs regarding Rule 35d-1 of the Investment Company Act of 1940, as amended (Names Rule). As you may recall, the SEC adopted the Names Rule amendments in September 2023, extended the compliance date in March 2025, and have published multiple rounds of FAQs. In tandem with these new FAQs, the SEC has delayed compliance with certain N-PORT amendments that related to the Names Rule. More information on the N-PORT amendments can be found in our Blog Post.
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