United States: From Fast Track to Fine-Tuned: How the SEC’s New Form N-PORT Amendments Refine the Rules for Fund Reporting
By: Thoreau A. Bartmann and Christine Mikhael
On 19 February 2026, the SEC proposed further amendments to Form N-PORT (2026 Proposal). In August 2024, the SEC adopted amendments to Form N-PORT that required more frequent and accelerated reporting for registered investment companies (the 2024 Amendments). The 2024 Amendments would have required registered investment companies to file monthly Form N-PORT reports within 30 days of month-end and would have required information related to the newly amended Investment Company Act Names Rule (Names Rule).
The 2026 Proposal reduces the filing frequency of N-PORT to quarterly, eliminates reporting related to the recently adopted Names Rule, and reduces certain recordkeeping requirements. Notably, the 2026 proposal does add a new reporting requirement related to the SEC’s recent dual share class orders. Under the 2026 Proposal, mutual funds with ETF share classes would need to disclose the ETF share class’s net assets and flows into and out of the share class during the period.
The 2026 Proposal differs from the 2024 Amendments in the following key ways:
| 2024 Amendments | 2026 Proposal | |
|---|---|---|
| Filing Deadline | 30 days after month-end | 45 days after month-end |
| Public Disclosure | Monthly, 60-day delay | Quarterly (third month), 60-day delay |
| Portfolio Level Risk Metrics Threshold | 25% of net assets in debt | 50% of net assets in debt |
| Names Rule Reporting | Required | Eliminated |
| ETF Share Class Data | Not required | Required to report net assets and flows separately |
| Ticker/Class Identifiers | Not required | Required |
| Recordkeeping | 30-day requirement | Eliminated |
In a related action, the SEC separately adopted rule amendments that will extend the compliance date for the Names Rule related requirements of N-PORT to 17 November 2027 for larger funds and 18 May 2028 for smaller funds, as the SEC considers the 2026 Proposal.
We expect that registrants will generally appreciate the proposed streamlined filing requirements, as it in many ways it returns to the previous status quo. We do expect that filers may wish to share their views on the new ETF share class reporting requirements. The comment period will end 60 days after publication in the Federal Register and comments may be submitted here.