On April 16, 2025, the Securities and Exchange Commission (SEC) extended the compliance dates for the amendments to Form N-PORT.  The SEC previously adopted amendments to Form N-PORT to require more frequent reporting of monthly portfolio holdings and related information, and to amend certain reporting requirements relating to entity identifiers.  In the same release, the SEC also adopted amendments to Form N-CEN and provided guidance on liquidity risk management program requirements for open-end funds.

The extension of the compliance dates is based on (i) the January 20, 2025, Executive Order directing agencies to consider postponing for 60 days the effective date for any rules that had been issued but had not yet taken effect for the purpose of reviewing any questions of fact, law, and policy that the rules may raise, (ii) the issuance of a stay by the Fifth Circuit Court of Appeals in a proceeding brought by the Registered Funds Association seeking review of the final amendments to Form N-PORT, and (iii) receipt by the SEC of a letter from the Investment Company Institute requesting further amendments to Form N-PORT due to concerns about the potential negative impacts of certain of the recent amendments.

In light of these developments, the SEC extended the effective and compliance dates of the amendments to Form N-PORT to provide it time to complete its review in accordance with the Executive Order and take any further appropriate actions, which may include further proposed amendments to Form N-PORT.  The new effective date for the Form N-PORT amendments is November 17, 2027, and the new compliance dates are as follows:

If the Commission determines that no further amendments to Form N-PORT are needed, the extended effective and compliance dates are intended to provide funds with sufficient time to comply with the amendments after being notified that the SEC’s review is complete.

The amendments to Form N-CEN and the guidance on liquidity risk management program requirements were not specifically challenged in the pending litigation.  The SEC has completed its review of them in accordance with the Executive Order and is not proposing any changes.  As a result, the effective and compliance date for the Form N-CEN amendments remains November 17, 2025.